HomeMy WebLinkAboutAIS PLANNER 7/2/2007
Meeting Date: July 2"', 2007
Meeting Type: Work Session IRegular Session
Department: Development Services
Staff Contact: David Reesor '\. ,'\ ~
S P R I N G FIE L D Staff Phone No: 726-3783 7lP- I'\~
C IT Y C 0 U N C I L Estimated Time: 20 minutes I 20 minutes
ITEM TITLE: CONCURRENT METRO PLAN; REFINEMENT PLAN MAP AMENDMENT AND
ZONING MAP AMENDMENT REGARDING PROPERTY NEAR 44TH & MAIN
STREET. .-
Conduct a public hearing and adopt/not adopt on the following ordinances:
AGENDA ITEM SUMMARY
ACTION
REQUESTED:
ISSUE
STATEMENT:
ATTACHMENTS:
DISCUSSION;
FINANCIAL
IMP ACT:
AN ORDINANCE AMENDING THE METRO PLAN DESIGNATION OF
APPROXIMATELY 5.24 ACRES OF LAND, IDENTIFIED AS LANE COUNTY
ASSESSOR'S MAP 17-02-32-00, TAx LOTS 400 & 402 FROM LIGHT MEDIUM
INDUSTRIAL (LMI), TO COMMERCIAL WITH AN AUTOMATIC REDESIGNATION
TO THE EAST MAIN REFINEMENT PLAN FROM LMI TO COMMUNITY
COMMERCIAL (CC).
AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP BY REZONING
APPROXIMATELY 5,24 ACRES OF LAND IDENTIFIED AS LANE COUNTY
ASSESSOR'S MAP 17-02-32-00, TAX LOTS 400 & 402, FROM LIGHT MEDIUM
INDUSTRIAL (LMI) TO COMMUNITY COMMERCIAL (CC).
The applicant requests approval of a Metro Plan; Refmement Plan Map Amendment to the
East Main Refinement Plan and a concurrent Zoning Map Amendment The request
involves two parcels, and is located on approxinlately 5,24 acres identified as Tax Lots 400
and 402 on Assessor's Map No. 17-02-32'00. Specifically, the applicant proposes to
change the Metro Plan designation from'Light Medium Industrial (LMI) to Commercial and
a concurrent Refinement Plan Amendment and Zoning Map Amendment from LMI to CC.
The applicant seeks approval of these applications in order to facilitate development of a
future Medical Office building on the site,
Attachment I: Ordinance Amending the Metro Plan & East Main Refinement Plan
Attachment 2: Ordinance Amending the Springfield Zoning Map
Attachment 3: Plaffiling Commission Order & Recomnlendation
Attachment 4: Staff Report with exhibits
On June 5'h, 2007, the Plaffiling Commission held a work session and public hearing on the
subject applications (LRP2007-00013 & ZON2007-00012). One citizen, Nancy Falk,
testified in opposition to the proposal at the first public hearing and requested that the
record be left open for seven days. The Plaffiling Commission granted the request and
instructed Staff to leave the record open until Tuesday, June Ith, 2007, Staffreceived one
written testimony from Lauri Segel, Goal One Coalition P1affiler, on June 12'",2007. A
written rebuttal to Ms, Segel's letter was then submitted by the applicant the following day,
June 13'h, 2007. Both letters were received within the specified deadlines as noted in the
Planning Commission public hearing on June 5"', 2007. The original Staff Report and
exhibits are attached for Council's review. .
After reviewing all oral and written testimony, the Plaffiling Commission deliberated on the
applications on June 19'h, 2007, and voted unanimously (5-0) to recommend that both
applications be sent to the City Council for consideration and approval.
. Date Received:
Planner: DR
'} {:rIO'}
,(/'z_5' '/?/T<.c'5)
ORDINANCE NO.
AN ORDINANCE AMENDING THE METRO PLAN DESIGNATION OF APPROXI-
MATEL Y 5.24 .ACRES OF LAND, IDENTIFIED AS LANE COUNTY ASSESSOR'S MAP 17-
02-32-00, TAX LOTS 400 & 402 FROM LIGHT MEDIUM INDUSTRIAL (LMI), TO COM-
MERCIAL WITH AN AUTOMATIC REDESIGNA TION TO THE EAST MAIN REFINE-
MENT PLAN FROM LMI TO COMMUNITY COMMERCIAL (CC).
(General)
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
I. Article 7 of the Springfield Development Code sets forth procedures for Metro Plan dia- .
gram amendments; and
2, Springfield Development Code Section 7,\ 10(4) states:
"When a Metro Plan amendment is enacted that requires an amen'dment to a refinement
plan or fimctional plan diagram or map for consistency, the Metro Plan diagram
amendment automatically amends the r~/inement plan or./imctional plan'diagram or map
if no amendment to the refinement plan or fimctional plan text is involved... " ; and
3, Article 8 of the Springfield Development Code sets forth procedures for Refinement Plan
. diagram anlendments; and
4. On March 16'h, 2007 the applicant/owner of the subject property initiated the following
Metro Plan Diagram amendment with automatic amendment to the East Main Refinement Plan:
Redesignate approxinlately 5.24 acres ofland on-the Metro Plan Diagram from Light
Medium Industrial to Commercial with automatic redesignation of said property on the
East Main Refinement Plan diagram from LMI to Community Commercial (CC), Case
Numher LRP2007-00013, for property identified as Lane County Assessor's Map 17-02-
32-00, Tax lots 400 & 402; and
5. On June 4"', 2007, the Springfield Plaffiling Commiss,ion held a work session and public
hearing to receive testimony and hear comments on this proposal. A second public hearing was
held on June 18''', 2007 after the written record was left open for seven additional days and after
reviewing additional written testimony, The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City Council; and
6. On July 2"d, 2007 the Springfield City Council held a work session and a public hearing
to consider and to receive testimony and hear comments on this proposal. The City Council is
now ready to take action on this proposal based upon the above recommendation and the evi"
, dence and testimony already in the record as well as the evidence and testimony presented at this
public hearing held in the matter of adopting this Ordinance amending the Metro Plan Diagram
and East Main Refinement Plan Map,
NOW THEREFORE, based upon the foregoing findings 1-6 the City of Springfield or- '
dains as follows:
Section I. The Metro Plan designation of the subject property, more particularly de-
scribed in Exhibit A attached. hereto and incorporated herein by reference, is hereby
amended from Light Medium Industrial to Commercial.
ORDINANCE NO,
A liMOl-'fM ENT
1-1
Section],. The East Main Refinement Plan designation of the subject property is hereby
amended from Light Medium Industrial to Community Commercial.
Section 3, If any section, subsection, sentence, clause, phrase, or 'portion of this Ordi-
nance is for any reason held invalid or unconstitutional by any court of competent juris-
diction, that portion shall be deemed a separate, distinct, and independent provision and
that holding shall not affect the validity of the remaining portion of this Ordinance,
FURTHER, although not part of this Ordinance, the Springfield City Council adopts'
findings I -6 herein above, and the findings set forth in the Staff Report which demonstrate con-
fOffilance of this amendment to the Metro Plan, applicable State statutes and applicable State-
wide Planning Goals and Administrative Rules, and is attached as Exhibit A,
ADOPTED by the Common Council of the City of Springfield this
, 2007 by a vote of _ for and _ against.
day of
APPROVED by the Mayor of the City of Springfield this_ day of
,2007.
Mayor
ATTEST:
City Recorder
ORDINANCE NO.
PAGE 2 OF 2
1-2
, ORDl.1~ANCE NO,.
AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP BY REZONING
APPROXIMATELY 5.24 ACRES OF LAND IDENTIFIED AS LANE COUNTY ASSESSOR'S
MAP 17-02-32-00, TAX LOTS 400 & 402, FROM LIGHT MEDIUM INDUSTRIAL (LMI) TO
COMMUNITY COMMERCIAL (CC).
, (General)
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
I. Article 12 of the Springfield Development Code sets forth procedures for Springfield
Zoning Map amendments; and
2, On March 16'h, 2007 the applicant/owner of the subject property initiated the following
Springfield Zoning amendment:
Rezone approximately 5.24 acres ofland from Light Medium Industrial to Community
Commercial, Case Number ZON2007-00012, for property identified as Lane County As-
sessor's Map 17-02-32-00, Tax lots 400, and 402; and.
3, On June 4''', 2007, the Springfield Plaffiling Commission held a work session and puh1ic
hearing to receive testimony and hear comments on this proposaL A second public hearing was
held on June l8'h, 2007 after the written record was left open for seven additional days and after
reviewing additional written testimony. The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City Council; and
4. On July 2"", 2007 the Springfield City Council held a work session and a public hearing
to consider and to receive testimony and hear comments on this proposaL The City Council is
now ready to take action on this proposal based upon the above recommendation and the evi-
dence and testimony already in the record as well as the evidence and testimony presented at this
public hearing held in the matter of adopting this Ordinance amending the Springfield Zoning
Map. ..
NOW THEREFORE, based upon the foregoing findings the,City of Springfield ordains
as follows: .
Section I. The Springfield Zoning Map, more particularly described in Exhibit A at.
tached hereto and incorporated herein. by reference, is hereby amended from Light Me-
dium Industrial to Community Commercial.
Section 2, If any section, subsection, sentence, clause, phrase, or portion of this Ordi-
nance is for any reason held invalid or unconstitutional by any court of competent juris-
diction, 'that portion shall he deemed a separate, distinct, and independent provision,and
that holding shall not affect the validity of the remaining portion of this Ordinance.
FURTHER, although not part of this Ordinance,the Springfield City Council adopts
findings I -4 herein above, and the findings set forth in the Staff Report which demonstrate con-
formance of this amendmen) to Section 12,030 of the Springfield Development Code and to ap-
plicable Statewide Planning Goals,and is attached as Exhibit A.
ORDINANCE NO.
ATIf~HMENT
2-1
"
. ADOPTED by the Common Council of the City of Springfield this
. 2007 by a,vote of _ for and _ against.
APPROVED by the Mayor of the City of Springfield this_ day of
Mayor
ATTEST:
City Reco~der^
ORDrNANCE NO.
PAGE20F2
2-2
day of
2007,
. BEFORE THE PLANNING COMMISSION
OF THE CITY OF SPRINGFIELD
ORDER AND RECOMMENDATION
FOR A METRO PLAN I EAST MALl'{
STREET REFINEMENT PLAN MAP
AMEJI,'DMENT AND A ZONING MAP
AMENDMENT
+
+
+
+
CASE NO. Ll~P2007-000I3
CASE NO. ZON2007-00012
FINDING, CONCLUSIONS
AND RECOMMENDATIONS
RECOMMENDATION TO CITY COUNCIL
NATURE OF THE APPLlCA TION
This is a consolidated application for the above referenced case numbers. The applicant requests approval
of a Metro Plan! East Main Refinement Plan Map Amendment and a concurrent Zoning Map
Amendment on properties identified as Lane County Assessor's Map No, 17-02-32-00, Tax Lots 400 and
402. The request involves two contiguous properties near 44'h and Main Street. Specifically, the applicant
proposes to change Metro Plan designation from Light Medium Industrial to Commercial and a
concurrent Reflllement Plan Map and a Zoning Map Amendrrient from LMI to CC.
I. The subject applications for a Metro Plan! Refmement Plan map amendment and Zoning Map
Amendment were submitted to the Development Services Department on March 16'~, 2007, and
deemed as complete on April Il'h, 2007.
2, The application was submitted in accordance with Section 3.050 of the Springfield Development
Code, Tinlely and sufficient notice of the public hearing, pursuant to Section 14.030 of the
Springfield Development Code, has been provided, '
3. On June 5~, 2007 a public hearing on the zone change request was held. The Development
Services Department staff notes including criteria of approval, findings and recommendations,
together with the testinlony and submittals of the persons testifying at that hearing have been
considered and are part of the record of this proceeding.
4. On June 19~, 2007 the Plaffiling Commission considered additional information submitted into
the record as of June 13'h, 2007,
CONCLUSION
On the basis of this record, the proposed amendments are consistent with the criteria of Sections 7.070,
8,030 and 12.030 of the Springfield Development Code. This general flllding is supported by the specific
findings of fact and conclusions in the attached staff report and attached hereto.
ORDER
It is ORDERED by the Plaffiling Commission of Springfield that approval of Case Number LRP2007-
00013 and ZON2007-00012, be GRANTED and a RECOMM~A1;ION for approval forwarded to the
Spnngfield City Council. This ORDER was presented to a H o..eft by the Planlllng CommisslOn on
June 19'h, 2007. I'
Pia' n Co ' Ission ChairjJerson '
ATTEST:
AYES: . 2
NOES: $L
ABSENT: .3c:
ABSTAIN: L
ATTACHMENT
3-1
SPRINOPIJD..D
. Type II Metro Plan Map Amendment
& Zoning Map Amendment
Staff Report and Findings
Hearing Date:
June 4m, 2007 - Planning
Commission
June 18th, 2007 -
Planning Commission
July 2nd, 2007 - City
. Council
Aoolicant
Case Number:
ZON 2007-00012
LRP 2007-00013'
PeaceHealth Oregon Region
123 International Way
Springfield, OR 97477
Hyland Business Park, LLC (TL 400)
Alln: Shaun Hyland
1941 - A Laura Street
Springfield, OR 97477
Andrew Head (TL 402)
1616 Ardendale Ln.
Eugene, OR 97405
Aoolicant's
ReQresentative
Philip Farrington, AlCP
Director, Land use
Planning & Development
PeaceHealth Oregon
Region
123 I nternational Way
Springfield, OR 97477
Owner
Date Submitted: March 16th, 2007
EXECUTIVE SUMMARY:
The applicant is seeking approval of a Metro Plan Amendment! Refinement Plan .
Amendment and a concurrent Zoning Map Amendment from Light Medium Industrial
(LMl) to Community Commercial (Ce). As described in the Springfield Development
Code, a Refinement Plan Amendment automatically occurs on a site concurrently with a
Metro Plan Amendment if no new Refinement Plan text is needed or proposed. The
applicant is requesting these amendments in order to pursue a future Medical Office.
building on the subject site. The subject site is located within the East Main Refinement
Plan area.
The subject site is located near 44th and Main Street (Highway 126). The site consists of
two parcels, and is located on approximately 5.24 acres identified as.Tax Lots 400 and
402 on Assessor's Map No. 17-02-32-00, The majority of the site is vacant (TL 400), with'
some small vacant buildings on site. The smaller of the two subject lots, TL 402, has an
existing commercial development on-site. Properties located to the north are zoned and
designated heavy industrial. Parcels located west of the subject site are designated
mixed-use on the East Main Refinement Plan. Property located east of the subject site is
designated LMI. Properties located south of the subject site, across Main Street, are
zoned and designated Community Commercial.
As mentioned in findings in this report, Staff supports the proposed Metro Plan!
Refinement Plan and Zoning Map Amendment. As noted in the City of Springfield's 2000
LRP1007-000/3 & ZON1007-00011
ATTACHMENT
A-1
I
Commercial Lands Study, there is a shortfall of commercial lands within city limits, The.
1992 Industrial Land Inventory and the City's adopted Goal 5 analysis support the fact
that there is a surplus of industrial land in the Metro area, The Metro Plan allows
amendments such as that which is proposed to allow City's to modify land use patterns
as demand and the community's vision change over time. The p'roposed Metro Plan
Amendment is a Type II Amendment, meaning it is site specific and is located within the
city limits,
In order to approve these applications, the applicant must demonstrate compliance with
the Statewide Planning Goals, Metro Plan, Oregon Administrative Rules, State Statutes,
and demonstrate the ability to service the site with adequate public facilities and
services.
,
T.his Staff Report provides findings of fact relevant to each of the applicable criteria of
approval and recommendations to the Planning Commission. Upon review of the
evidence provided by the applicant, site visits, existing structuresluses and review of the
applicable criteria of approval, staff finds that the applicant's request for a Metro Plan!
Refinement Plan Amendment and concurrent Zoning Map Amendment from LMI to CC
is appropriate for the subject property and recommends the Planning Commission
approve the attached Order and forward the proposal to the City Council with a
recommendation for adoption, .
REQUEST:
The applicant is requesting approval to change the map designation on the Metropolitan
Area General Plan ("Metro Plan") diagralT\ from Light Medium Industrial (LMI) to
Commercial for approximately 5.24 acres located near Main Street and 44th Street. A
Metro Plan Amendment at this time (not during Periodic Review) is known as a Post
Acknowledgement Plan Amendments (PAPA). This same acreage on the site is being
proposed for a concurrent amendment to the Springfield zoning map from LMI to
Community Commercial (CC), as allowed in Springfield Development Code (SDC)
12.020 (1 )(a)1.
Pursuant to SDC 7.110 (4), approval of the requested Metro Plan diagram amendment
automatically amends the refinement plan diagram and is process.ed concurrently.
Findings of fact addressing the criteria of approval in SDC 7.070(3) are included in the
applicant's narrative statement and in this report.
SITE DESCRIPTION:
,The subject site is located on approximately 5.24 acres identified as Tax Lots 400 and
402 on Assessor's Map No. 17-02-32-00.
The subject properties include a vacant, flat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) east of 44th Street along Main Street in east
Springfield. . The site is bordered on the south by Main Street, on the east by the Hyland
Business Park, on the north by an open area south of the Weyerhaeuser mill site (Tax
Lot 400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by
other small-scale commercial enterprises (e.g., a cabinet shop and karate school)
fronting Main Street and residential homes along 44th Street west of Tax Lot 400,
1
lRP1007-000/3 & ZON1007-000/1
4-?
Commercial enterprises are located immediately south of the site across Main Street
(e.g., Gray's Garden Center),
While historically involved in agricultural uses, since around 1990 Tax Lot 400 was used
as a storage and sales yard for landscape organics and forest by-products. The current
,property owners also used the site to store modular construction offices, tool trailers,
construction equipment and concrete form plywood. Tax Lot 402 has had various
commercial services on site since the 1950s.
The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic
resources. The site is within the Springfield Urban Growth Boundary, and both parcels
were annexed into the City of Springfield in 1960. The East Main Refinement Plan
(EMRP) diagram (adopted in 1988) currently designates the subject property for
industrial uses.
The abutting property to the east is designated Light/Medium Industrial in the EMRP
diagram and zoned LMI. The areas immediately to the west ancj south of the site
fronting Main' Street are identified as being within Mixed-Use Area #2 in the EMRP, and
are all zoned Community Commercial. Property to the west of Tax Lot 400 along 44th
Street is zoned and designated Medium Density Residential.
lRP2007-000/3'& ZON2007-000/2
3
~?
Existing & Proposed Metro Plan Designation:
/\ I I IJ,,/L
"v/ .. j--L
'~"/' 1.--;-
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: ''''. . "-../\ r--L' . ~'-c-'--
'" " /) .~.
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---"--"j i _'0
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..------__..J__----..l..,..--.J
I i
"~oj'"~
"".. 'c...."".
.~ ...,'.",
IG ..,
.. . .
. . ,~~ . .'
~ Change from Light Medium Industrial to Commercial
Metro Plan Designation .
_ Commercial MU
1,< 1 Light Med. Indus!.
D Low Den. Res.
D Med. Den. Res.
_ Heavy Industrial
~~
1h1!Te ore no Mlarranne:r fha/aceanpan)' thi~prodw;(
Us~n Q=me all rer/XJflsibihryjOrany Ion OT'dama~arlsl"g
fromany uro~. omissi"" <T pninona! inaca.rOcyofthi.s prodr.cr
'"
:00 "'.
June, 2007
LRP2007-000/3 & ZON2007-000/2
4
l
Existing & Proposed Refinement Plan Designation:
Ml'JNST
~
I
~
~
00
~
00
I
~
~
00
_Till
( I
I i
I~I'-I' ~"~"."'~
~W,~ ~~.,h~'_" .",~",
.,'",lh'ii!: ..~~ < ..,':{1::!";,;,i,
. 8._ .&'i~ ~':-'l~\
~ Change from Light Medium Industrial (LMI) to Community Commercial (CC)
Refinement Plan
_ Community Commercial
Low Densrty Residential
!llm Medium Density ResidentiaJ
1l\:i!1 Ught-Medium Industrial
;;;,;; Heavy Industrial
Im!lI Mixed Use 2 & 3
~~~ ~=.:~";;;;,,,';:;:;,,-:;r.~':f=:;."~"g
.... < fromarryenw,omIssiOI1<rfDSitionallnOcw.racyofthisprotiucr
100 3lOFeet
June, 2007
LRP2007.{JOO /3 &:ZON2007-000 /2
5
,
Existing & Pro
posed Zoning:
m Olange from L' '
ZOnlrg ght Medium Ind . '
_ Medium Densi ' ustnal (LMI) to Communit
Low Dens"y R ty ResIdential y Commercial (CC)
~ ,Communi eSldential
Miliq Ught Med~~merdal
_ Haavy Jrdustri;ldustnal
~~~
71un(11Y""lO'amlIl
Us,nlUSUmtaOr IleJthmfNXO"fW/fY
jivmanym"Or. ~pon.riblfjtyp,.an ~uprrxiuct.
.omwlonU'{X)Siriona~lnac ordamag.,(ZrWng
. anucyofrhi!J product
'"
~Feet
June, 2007 '
lRP2007-000 13 & Z
ON2007-00011
6
'",.' Existing Site Conditions:
Existing commercial uses on TL 402
I Existing modular units located on TL 400
lRP2007:000 /3 & ZON2007-000 12
Existing empty structures on TL 400
Existing business' park on property located east of TL
400
7
REVIEW PROCESS:
The proposed Metro Plan Amendment is a Type ,II Amendment because it is located
inside the city limits and is.site specific. The applicant has requested that application
ZON2007-00012 (Zoning Map Amendment) be raised to a Type IV review procedure
and be reviewed concurrently with the Type II Metro Plan! Refinement Plan Amendment
Application LRP2007 -00013. These two applications use similar criteria of approval and
have been combined into one staff report for ease of review, Both applications have
criteria requiring consistency with the Metro Plan and other similar criteria, Rather than
repeat these criteria for each application, they will be addressed only once and then
referenced where appropriate. Criteria that are different will be addressed separately;
the end result will be that all applicable criteria will have been addressed.
This application was submitted to the Development Services Department on March 16'",
2007, and deemed as complete on April 11'", 2007. Notice for both applications was
mailed to Department of Land Conservation and Development (DLCD) on April 16'",
2007. Notice of the public hearing date was mailed out on Thursday, April 19, 2007 to
property owners within 300 feet of the proposed zone change per S,ection 14.030 (1) (a)-
(n) of the SDC, Public notice' of the hearing was published in the local newspaper
(Register Guard) on May 1ih, 2007, as required in Section 14.030 (2) of the SOC. No
written comments were submitted at the time of issuing this report.
METRO PLAN DESIGNATION:
The subject property is designated LMI as shown in the Metro Plan diagram. The
subject property is part of the East Main Refinement Plan (EMRP), which provides a
more localized scope related to Plan Designation, The subject property is designated
LMI on the Refinement Plan Diagram. Specific Findirigs related to the Metro Plan and
EMRP Street Refinement Plan Designation are written in this report.
METRO PLAN DIAGRAM AMENDMENT . .
CRITERIA OF APPROVAL - SDC 7:070(3)(a)-(b)
"The following criteria shall be applied by the City Council in approving or denying a
Metro Plan amendment application:
. (a) The amendment must be consistent with the relevant Statewide
planning goals adopted by the Land Conservation and Development
. Commission; and
(b) Adoption of the amendment must not make the Metro Plan internally
inconsistent. "
CRITERIA OF APPROVAL - SDC 7.070 (3)(a)
APPLICANT'S NARRATIVE:
Consistency with Statewide Planning Goals:
LRP2007-0001.3 & ZON2007-000/2
8
4-R
The following findings address compliance ro'ithMetro Plan criteria in SDC 7.070 (3)(a).
Approval of a Metro Plan diagram amendment also correspondingly changes' the
applicable refinement plan diagram, as established in SDC 7,110 (4).
APPLICANT'S NARRATIVE RELATED TO GOAL 1:
Goal 1 _ Citizen Involvement: To develop a citizen involvement program that insures
the opportunity for citizens to be involved in all phases of the planning process.
Goal 1 addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use planning process, The Planning Commission
and the City Council will hold public hearings and accept testimony on the proposal.
Through the procedures established by the city, citizens will receive notice of hearings in
generally published local papers and have the opportunity to be heard regarding the.
proposed diagram amendment and zone change, Notice of the public hearings will also be
given' in accordance with SDC requirements to nearby property owners, interested parties
requesting notice, and any established neighborhood organization.. Since the
amendments comply with the City's citizen involvement program and citizens have
. opportunities to be involved in the procedure, the proposed amendments are consistent
with Goal 1, ,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 1:
Finding 1: These applications comply with Goal 1 because they are being reviewed
under an acknowledged citizen involvement program.
As previously mentioned in this report, notice for both applications was mailed to
Department of Land Conservation and Development (DLCD) on April 16th, 2007.
Notice of the public hearing date was mailed out on Friday, May 11th, 2007 to
property owners within 300 feet of the proposed zone change per Section 14.030 (1)
(a)-(n) of the SOC. Public notice of the hearing was published in the local newspaper
(Register Guard) on May 1th, 2007, as required in Section 14.030 (2) of the SDC,
Staff c,?ncurs with the applicant's written statement related to Goal 1 ,
. APPLICANT'S NARRATIVE RELATED TO GOAL 2:
Goal 2: Land Use Planning: To establish a land use planning process and' policy
framework as a basis for all decision and actions related to use of land and to assure
an adequate factual base for such decisions and actions.
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local
comprehensive plans be internally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans. Goal 2 also requires that land
use decisions be coordinated with affected jurisdictions and that they be supported by
an adequate factual base. As required in SDC 7.050, the City is required to give
referral notice of the proposed Type II Metro Plan diagram amendment to the City of
Eugene and Lane County so they may determine if there are grounds to participate as
parties to the hearing. The City also sends the statutorily required notice of the initial
public hearing 45 days in advance to the state Department of Land Conservation and
Development, ensuring that they are given opportunity for comment and review
confor,mity to applicable statewide planning goals.
LRP1007-000/3 & ZON1007-000/1
9
4-9
The Metro Plan and the'SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and' criteria for the evaluation of comprehensive plan
amendments. Compliance with these measures assures an adequate factual base for
approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and the Goals.
Consequently, by demonstrating such compliance, the amendments satisfy the '
consistency element of Goal 2,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 2:
Finding 2: These applications comply with Goal 2 because the SDC requires
consistency between the Statewide Planning Goals, the acknowledged Metro Plan,
adopted refinement plans and special area plans and the zoning.
Staff concurs with the applicant's written statement related to Goal 2.
APPLICANT'S NARRATIVE RELATED TO GOAL 3:
Goal 3 - Agricultural Land: To preserve and maintain agricultural lands,
This goal is inapplicable because 'as provided in OAR 660-15"000(3), Goal 3 applies only to
rural agricultural lands. The subject properties are located within an acknowledged urban
growth boundary, are inside Springfield's corporate limits, and have not been in
agricultural ,use for decades.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 3:
Finding 3: The subject property is located within the: city limits on land planned and
zoned for urban use. The City does not have any agricultural zoning districts, either
within its city limits or within the urban growth boundary.
Finding 4: Goal 3 does not apply to these applications because the subject property
is within Springfield's city limits.
APPLICANT'S NARRATIVE RELATED TO GOAL 4:
Goal 4 _ Forest Land: To conserve forest lands by maintaining the forest land base
and to protect the state's forest economy by making possible economically efficient
forest practices that assure the continuous growing and harvesting of forest tree
species as the leading use on forest land consistent with sound management of soil,
air, water, and fish and wildlife resources and to provide for recreational opportunities
and agriculture.
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendments are inside Springfield's acknowledged UGB;
i
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 4:
Finding 5: The subject property is located within an acknowledged urban growth
'boundary, Goal 4 does not apply within urban growth boundaries, Staff concur with
the applicant's written statement related to Goal 4.
LRP2 00 7-000 13,& ZON2007-00012
10
4-111
...;
APPLICANT'S NARRATIVE RELATED TO GOAL 5:
Goal 5 _ Open Spaces', Scenic and Historic Area, and Natural Resources: To conserve
open space and protect natural and scenic resources.
Goal 5 requires local governments to protect a variety of open space, scenic, historic, and
natural resource values. Goal 5 and its implementing rule, OAR Ch. 660, Division 16,
require planning jurisdictions, at acknowledgment and as a part of periodic review, to
(1) identify such resources;
(2) determine their quality, quantity, and location;
(3) identify conflicting uses;
(4). examine the economic, social, environmental, and energy (ESEE)
consequences that could result from allowing, limiting, or prohibiting
the conflicting uses; and
(5) develop programs to resolve thll conflicts.
The subject properties are not on Springfield's acknowledged Metro Plan Goal 5 inventory.
No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site. The
National Wetland Inventory and. Springfield Local Wetland Inventory maps have been
consulted a,nd there are no jurisdictional wetlands located on the site. Therefore, the
proposed amendment does not alter the City's compliance with Goal 5.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 5:
Finding 6: Goal 5 does not apply to these applications because there are no
inventoried resources on the subject property. Oregon Administrative Rule 660-023-
0250 establishes the applicability of Goal 5 rules to Post Acknowledgement Plan
Amendments (PAPA), the requested Refinement Plan Amendment and Zoning Map
Amendment do not affect the Metro Plan's adopted Goal 5 inventory. Staff concurs
with the applicant',s narrative related to Goal .5 compliance.
APPLICANT'S NARRATIVE RELATED TO GOAL 6:
Goal 6 _ Air; Water and Land Resources Quality: To maintain and improve the quality
of .the air1 water and land resources of the state.
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires' that development comply with
applicable state and federal air and water quality standards, In the context of the
proposed Metro Plan diagram amendment, Goal6 requires that the applicant demonstrate
that it is reasonable to expect that applicable state and federal environmental quality
standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environmental clean-up list. A Phase 1
environmental assessment on the subject property was conducted and recommended
additional analysis. Upon recommendations through the Phase 2 environmental '
assessment a nominal quantity of soil (less than 10 cy) impacted by earlier/historic use
was removed from the site and properly disposed, Given the nominal impact generated by
historic uses on the site, it is reasonable to conclude that future development on the site
will be able to demonstrate compliance with City standards for water quality protection
LRP2007-000/3 & ZON2007-00012
II
J
L...
~_11
through the site plan review process, thereby complying with applicable state and federal
environmental quality standards.'
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6:
Finding 7: The proposed Metro Plan! Refinement Plan Amendment or Zoning Map
Amendment does not modify any of the Goal 6 related policies of the Metro Plan, nor
do they amend the Regional Transportation Plan, the Springfield Development Code,
other applicable Goal 6 policies, or any regulations implementing those policies.
,
The subject property is located in the Zone of Contribution and outside any of the
Time of Travel Zones, which is regulated by the Drinking Water Protection .Overlay
District _ Article 17. Any new development on. the subject property is subiect to
compliance with Article 17 and other applicable regulations'related to Goal 6, Staff
concurs with the applicant's narrative related tO,Goal 6 compliance.
APPLICANT'S NARRATIVE RELATED TO GOAL 7:
Goal 7 _ Areas Subject to Natural Disasters and Hazards: To prote'ct /ife and property
from natural disasters and hazards. .
Goal 7 requires that development subject to damage from natural hazards and
disasters be planned andlor constructed with appropriate safeguards and mitigation.
The goal also requires that plans be based on an inventory of known areas of natural
disaster and hazards, such as ar~as prone to landslides, flooding, etc.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 7:
Finding 8: Staff has reviewed the natural constraints map and the FEMA Floodplain
Map in relation to the subject property, As noted by the applicant, the subject site IS
not included in the City's inventory of known areas of natural hazards. Staff concurs
with the applicant's narrative related to Goal 7 compliance,
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area. Therefore, approval of the proposed Plan
amendment and Zoning Map Amendment will not alter the City's acknowledged
compliance with Goal 7 through its adopted plans, codes and procedures.
APPLICANT'S NARRATIVE RELATED TO GOAL 8:
Goal 8.- Recreation Needs: To satisfy the recreational needs of the citizens of the state
and visitors and" where appropriate, to provide for the siting of necessary recreational
facilities including d,!stination resorts.
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citizens of the state and
visitors," and where appropriate, provide for the siting of recreational facilities including
destination resorts. The subject site is not included in an inventory of recreational sites,
and the proposed amendments will not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not implicate Goal 8.
l
lRP2007-000 /3 & ZON2007-00012
12
,Llry
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8:
Finding 9: Staff has consulted the Willamalane 20-year Parks and Recreation
Comprehensive Plan in relation to Goal 8 compliance, The Willamalane 20-year
Parks and Recreation Comprehensive Plan was adopted by the City of Springfield as
part of the Metro Plan's compliance with Goal 8. None of the various studies,
inventories, and facilities plans regarding recreational facilities In the adopted
Willamalane 20-year Parks and Recreation Comprehensive Plan have designated
the subject site for parks and open space in an adopted inventory, declared it a
significant resource, or slated it for acquisition. Staff concurs with the applicant's
narrative related to Goal 8 compliance,
APPLICANT'S NARRATIVE RELATED TO GOAL 9:
Goal 9 _ Economic Development: To provide adequate opportunities throughout the
state for a variety of economic activities vital to the health, welfare, and prosperity of
Oregon's citizens, '
Goal 9 requires the city to provide adequate opportunities for a variety of economic
activities vital to the health, welfare, and prosperity of the citizens, The proposed
amendment to the Metro Plan diagram will increase the city's capacity for economic
development by adding 5 acres of CC in place of the existing industrial designation,
Permitting the construction of future clinic facilities arid allowing long-standing
commercial uses on Tax lot 402 to become conforming uses consistent with commercial
zoning is consistent with numerous policies in the City's adopted plan for compliance with
Goal 9, the Springfield Commercial lands Study (SClS),
Specifically, the following SClS policies are applicable to the proposal:
Policy 1-A: "Maintain a mixed supply of large and small commercial sites through
strategies such as rezoning or annexation to serve Springfield's future population,"
, The proposal fulfills this policy objective by redesignating and -through accompanying
zone change _ rezoning land from industrial to commercial; for two tax lots of varying
sizes and commercial uses, thereby maintaining existing employment and commercial use
in Tax lot 402 and providing the ability for growth in medical sector employment by
allowing future clinic uses on Tax lot 400, ,
Policy 1-C: "Maintain at least a five-year supply of commercial land within the Urban,
Growth Boundary (UGB) that is currently served or readily serviceable with a full range of
urban public facilities and services,"
The SClS (see Table 3-8, pg. 32) found there to be a deficit of 158 acres in the supply of
commercial land over demand projected through the year 2015. The proposal would allow
for redesignation, and rezoning, of five acres thereby reducing the deficit of commercial
land. The subject site has a full range of urban public facilities and services available to
support existing commercial development on Tax lot 402, and future development on Tax
lot 400. The SClS identifies (pg. 33) a need to support "employment in population-
dependent sectors such as retail sales and health services" to meet Springfield's growing
community. The SClS also noted (pp, 27-29) state and local trends in greater employment
in retail trade and well-paying health services sectors, Approving the proposed
redesignation and zone change would help meet Springfield's demonstrated need for
employment and commercial services.
LRP2007-000/3 & ZON2007-.000/2
13
A-1<l
Finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area."Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit identified in the SCLS. Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy 3-A (1): "Evaluate inventories based on
demonstrated need for the planning period.' Initiate rezoning or redesignation of surplus
land uses where more appropriate for commercial, consistent with the Metro Plan,"
The proposal in fact consistentwith inventories for commercial and industrial lands
adopted by the City Council and acknowledged by DLCO as being consistent with Goal 9,
Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-0010(4))
call for amendments to land use designations "in excess of two acres within an existing
urban growth boundary from an industrial land use designation to a non-industrial use
designation" to have to address applicable planning requirements - such as consistency
with the Metro Plan and other local plan policies (Le" SCLS) or be ,consistent with an
economic opportunities analysis. The City can find that the proposal complies with
relevant local plan policies by converting one form or employment-generating ,land use to
another, without negatively impacting the supply of buildable lands for either category of
uses. The proposal enables co'ntinued use of the existing and long-standing commercial
center to continue to operate and provide employment opportunities, while also allowing
higher-value employment associated with future development on Tax Lot 400. These
types of employment-generating uses are among those identified in OAR 660-009-0005(6)
as eligible non-industrial employmeni activities that can justify approval of the proposed
Plan diagram amendment without the need foran economic opportunities analysis apart
from the SCLS, which OLCO acknowledged as fulfilling the City's obligations under Goal 9.
Because the requested redesignation and concurrent zone change implements SCLS
policies and does not result in a deficiency of needed industrial lands, and is otherwise
demonstrated to be consistent with relevant Metro Plan policies, approval of the request is
, consistent with the City's compliance with Goal 9 and applicable administrative rules
regarding Goal 9 implementation.
Additional Goal 9 information submitted by applicant on March 28th, '2007:
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local jurisdictions
and acknowledged by LCOC as being consistent with statewide planning goals and the
Metro Plan, specifically fulfilling the Eugene-Springfield area's obligations under Goal 9
(Economic Development), The Metropolitan Industrial Lands Inventory Report associated
with the MILS identified "about 1,688 constraint-free industrial acres....This supply
exceeds the projected demand over the next twenty years, which is between 650 to 1,1,72
acres." (pg. 73) .The Inventory Report also stated: "The 1,688 constraint-free acres may be
the best suited to meet short-term industrial demand, This portion of the supply also
exceeds the twenty year demand projection."
The City, performed subsequent analysis of industrial land supply as part of periodic
review requirements to demonstrate compliance with statewide planning Goal 5 (Natural
Resources). As shown in Attachment A, that analysis indicated that even removing the.
possible industrial acreage affected by Goal 5 protection measures (about 100 acres
debited from the Eugene and Springfield inventories) would leave a surplus of industrial
lands of between 1,600 and 2,122 acres metro-wide,
Staff's Goal 5 work also calculated the changes in industrial land supplies since 1991 as a
consequence of Metro Plan diagram changes (see AttachmentS). This analysis
demonstrated a reduction in less than 90 acres of industrial land over the past 15 years,
LRP2007-000/3 & ZON2007-000/2
14
1\_11\
SlJggesting that there is still an ample supply of available industrial lands to meet existing
and future development needs. '
This analysis may also not reflect other changes within industrially designated land
categories that would further off-set the proposed change to the site's LMI'Plan
designation and zoning. For example, 11.5 acres was added to the inventory of LMI zoned
and designated land due to City Council approval in April 1997 for land east of the 28lh/31"
Street connector and north of Marcola Road (Ordinance No. 5851). Insofar as the City and
metropolitan area continue to enjoy a surplus of needed Industrial land, and specifically
Heavy Industrial zoned and designated land, the above-referenced change added more
than enough acreage to the inventory of LMI designated and zoned land to off-set the
proposal to remove only about 5 acres from the LMI inventory.
We therefore respectfully submit that the proposed Metro Plan diagram amendment and
zone change will not materially affect the inventory of needed Industrial land and will not
alter the City's continued compliance with Goal 9.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 9:
Finding 10: The City of Springfield has two adopted inventories which support the
proposed Metro Plan Amendment! Refinement Plan Amendment and concurrent zone
change request - the 1992 Industrial Land Study and the 2000 Commercial Land Study.
The applicant references both of these adopted inventorjes and sites specific polices
. which support the proposal. As noted by the applicant, Finding 3 in the Springfield
Commercial Land Study (SCLS) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area." The applicant
also references Strategy 3-A(1) of the SLCS which states: "Evaluated inventories based
on demonstrated need for the planning period. Initiate rezoning or redesignation of
surplus land uses where more appropriate for commercial, consistent with the Metro
Plan." Staff finds that these referenced policies and adopted strategies support the
applicant's proposal. '
In addition to referencing the SCLS and the 1992 Industrial Land Study, the applicant
also references the adopted Goal 5 inventory work, which provides a more up-to-date
analysis of industrial lands in the Metro area. As noted in the City of Springfield Goal 5
analysis, even with a reduction of inventoried industrial land affected by Goal 5, there is
a still a surplus of between 1,600 arid 2,122 acres metro-wide.
,As noted by the applicant, Oregon Administrative Rules concerning Goal9
, implementation (OAR 660-009-0010) call for amendments to land use designations "in
excess of two acres within an existing urban growth boundary from an industrial land use
designation to a non-industrial use designation" to have to address applicable planning
requirements - such as consistency with the Metro Plan and other local plan policies
(i.e. SCLS) or new consistent with an economic opportunities analysis (EOA). OAR 660-
009-0010 states that a reviewing authority can find that the proposal complies with
relevant local plan policies by converting one form or employment-generating land use to
another, without negatively impacting the supply of buildable lands for either category of
,uses. As noted by the applicant, there are existing commercial uses located on TL 400
which are part of the subject property. Additionally, the applicant is seeking to develop
future commercial uses on the property which will maintain the property for employment-
generating activity. .
LRP2007-<J0013 & ZON2007-<J0012
15
d-11;
Given the information provided in the adopted commercial and industrial lands
inventories (a shortfall of commercial and an inventoried excess of Industrial land)
compared with the size of the proposed Plan'Amendment and Zone Change, staff find
that the proposal is consistent with Goal 9 requirements. Staff finds that the proposal
does not represent a "significant change" to the adopted EOA.
APPLICANT'S NARRATIVE RELATED TO GOAL 10:
Goal 10 _ Housing: To provide for the housing needs of citizens of the state,
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands. The proposal
does not affect the City's inventory of residential lands.
In fact, approval of the requested redesignation for Tax Lot 400would enable
redevelopment of an industrial site abutting existing' residential development. Through
the site plan review process, future development on that property will provide a superior
buffer and a higher use that will benefit the adjoining,residential properties. Because the
proposal involves redesignation from industrial to commercial land uses, it does not affect'
Springfield's continued compliance with Goal 10.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITHGOAL 10:
Finding 11 :.The proposed Metro Plan! Refinement Plan Amendment and Zoning
Map Amendment does not affect the Metro Plan's residential buildable lands
inventory because no residentially designated properties are involved in this
proposal.
The City of Springfield is currently working with a consulting company on a
residential land inventory and land supply analysis, When complete, this study will
update the City's inventory and provide a clear picture of residential land supply,
Staff concurs with the. applicant's response to Goal 10 compliance.
APPLICANT'S NARRATIVE RELATED TO GOAL 11:
Goal 11 _ Public Facilities and Services: To plan and develop a timely, orderly and efficient
arrangement of public facilities and services as a framework for urban and rural
development.
OAR 660-01'-0005(7)(a)-(d) Definition of Public Facilities:
(a) Water
(b) Sanitary Sewer
(c) Storm sewer
(d) Transportation
This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services, The subject property is located within the Springfield UGB and city
limits, and is already designated for urban levels of use. The proposed amendment to the
Plan map designations from LMI to CC will not affect the ability to provide needed services
since all the required urban services are available to support existing or future commerc,ial
uses on the subject site, .
LRP2007-00013 & ZON2007-000/2
/6
.d.-1.~
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 11:
Finding 12: As noted by the applicant, the Metro Plan and associatedfaGility plans
have been acknowledged to conform to Goal 11 ensuring that public facilities and
services are currently available to the subject site, The proposed Metro Plan!
Refinement Plan Amendment and Zoning Map amendment is on "infill" property,
which currently has city services available to the site. The proposal does not affect
the Metro Plan's compliance with Goal 11.
Finding 13: The subject Metro Plan! Refinement Plan Amendment and Zoning Map
Amendment applications have been reviewed by Public Works and Planning Staff to .
assure that there are adequate public services to serve the site, These applications
comply with Goal 11 because there are urban level public services available to the
subject property,
APPLICANT'S NARRATIVE RELATED TO GOAL.12:
Goal 12 _ Transportation: To provide and encourage a safe, convenient and economic
transportation system,
Goal 12 requires local governments to provide and encourage a safe, convenierit and
economical transportation system. The proposed map amendments involve
approximately 5.24 acres of property, though existing and long-standing commercial uses
occur on Tax Lot 402 such that approval of the proposal will not result in any changes to
the type or intensity of uses on the site, and will not increase the trip generation for that
p'arcel. As the attached Traffic Impact Analysis (TIA) demonstrates, future development of
medical office facilities on TL 400 will not degrade mobility standards below acceptable
levels and allow for adequate queuing lengths at applicable intersections, Therefore, the
proposal will not have a "significant effect" on transportation facilities as defined in the
Transportation Planning Rule (OAR 660-012-060).
Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to
retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some access changes aswill be reviewed
through the site plan review pr()cess, thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located approximately in the center of the parcel.
The TIA demonstrates that these access points will not result in any degradation of
mobility standards below acceptable levels, and that safe and efficient circulation can be
realized through approval of the requested land use redesignation (and companion zone
change).
Furthermore, reducing the number of access points for future development on Tax Lot 400
is consistent with policy objectives found in East Main Refinement Plan (EMRP) Access,
Circulation & Parking Element policy 1 B (pg. 17) and Commercial Element policy 3 (pg,
12),
Because the proposal, as demonstrated in the T1A, is consistent with the requirements ,of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and
applicable local implementing policies,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 12: .
Finding 14: The proposed Metro Plan Amendment is from LMI to Commercial, and
Refinement Plan Amendment I Zoning Map Amendment is from LMI to CC, The
applicant indicates in the submitted narrative that .approval of the proposal will not result
LRP2007-000 /3 & lON2007-00012
17
A-1:
'--
in any changes to the type or intensity of uses on the site, and will not increase the trip
generation for that parcel. Staff does not concur with this statement in reviewing all of
the potential CC uses on the site, Staff does concur; however, with the applicant's
statement if the future medical office use is in fact developed on the site, and not other
. potential "reasonable worse case" CC uses.
Pages 18-19 of the applicant's TIA list Peak Hour Trip Generation for both the existing
zone (LMI) and the proposed zone (CC). The applicant's TIA listed Peak Hour Trip
Generation for Medical Office Building. While this is a permitted use in the CC zone and
is the primary use that the applicant is seeking to use the property for, it is not the' .
"reasonable worse case" scenario for traffic generation given other allowable uses in the
CC zone. During Staff's review of the proposal, staff researched potential vehicle trips
per day for potential uses in the' CC zone. There are some other potential uses in the CC
zone which are much more intensive uses than Medical Office. In considering what a
"reasonable worst case" development scenario might be for the re-zoned condition it is
clear that a 30,000 square foot Medical Office Building is much less intense than other
uses that would be permitted in the CC zone. On a per-square-foot basis the Medical
Office is estimated to generate 2.47 vehicle tips/1 ,000 SF and 3.43 vehicle tips/1 ,000 SF
during the AM and PM peak hours respectively, For comparison the average rates for a
"Fast-Food Restaurant with Drive-Through Window" are 53.11 vehicle tips/1 ,000 SF and
34.64 vehicle tips/1 ,000 SF. These calculations are taken from the Institute for Traffic
Engineers (ITE) Manual.
As shown on Table 6 of the TIA, a reasonable worse case traffic generation scenario for
the existing zoning (LMI) is 243 trips, The proposed use of Medical Office Building is
shown in Table 7 as 177 trips. While the Medical Office use trip generation is less than
the reasonable worse case scenario for the existing zoning, it does not take into account
other more intensive commercial uses (Le, drive thru restaurants, banks, etc.). Planning'
Staff met multiple times with City Traffic Engineering Staff and ODOT Staff to review the
, submitted TIA. ODOT's review of the submitted TIA indicated that there were multiple
issues that were not adequately addressed in the submitted TIA to justify compliance
with Goal 12 (see attached memo from ODOT). Based upon the information provided in
the submitted TIA, all reviewing parties (I.e. City Planning Staff, City Traffic Engineering
Staff, and ODOT Staff) agreed on a recommended condition of approval (see attached
'emails from ODOT and City Traffic Engineering Staff). .In order to preserve the existing
and future road system, staff recommends that a trip cap be required as a condition of
approval not to exceed the reasonable worse case scenario for the existing zoning (243
trips). Because these numbers of trips are already allowed with the existing zoning, the
application complies with Goal 12.
Recommended Condition of Approval;
,
1. Trip generation from development on the subject property shall be limited to a
maximum ,of 243 PM Peak-hour vehicle trips, which is based on a "reasonable worse
case development scenario" under the existing zoning (LMI) as submitted by the
applicant in the Traffic Impact Analysis for the subject property.
LRP2007-000/3 & ZON2007~00/2
18
d-1Q
APPLICANT'S NARRATIVE RELATED TO GOAL 13:
, '
Goal 13 _ Energy Conservation: To conserve energy, Land and uses developed on the
land shall be managed and controlled so as to maximize the conservation of all forms
of energy,. based upon sound economic principles,' ,
The Energy goal is a general planning goal and provides limited guidance for site-specific,
map amendments, The proposed amendment has no direct impact on energy
conservation, though it would in fact will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.,
Therefore, the proposed amendment is consistent with, and does not alter the City's
continued compliance with Goal 13.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 13:
Finding 15: The proposed Metro Plan! Refinement Plan Amendment andZonirig
Map Amendment do not affect the Metro Plan's compliance with Goal 13. The
applicant is not proposing to' amend any regulation pursuant to Goal 13 compliance
of the Metro Plan.
APPLICANT'S NARRATIVE RELATED TO GOAL 14:
Goal 14 _ Urbanization: To provide for an orderly and efficient transition from rural to
urban land use.
Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from
rural to urban land usee" The subject property is within the UGB and the city limits of
Springfield, and within an existing urbanized area of,the community. Therefore, Goal 14 is
not applicable to this application.
I
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 14:
Finding,16: As noted by the applicant, all of the parcels affected by this application
are currently within the Urban Growth Boundary and were annexed into the City of
Springfield. All annexations are reviewed for compliance with the Metro Plan and th'e
Springfield Development Code, As previously mentioned, urban facilities are
available to the subject site. The proposed Refinement Plan and Zoning Map
Amendment are in compliance with Goal 13.
APPLICANT'S NARRATIVE RELATED TO GOAL 15:
Goal 15 _ Willamette River Greenway: To protect, conserve, enhance and maintain the
natural, scenic, historical, agricultural, economic and recreational qualities of lands
along the Wilfamette River as the Wilfamette River Greenway.
This goal is inapplicable because the subject property is not within the boundaries of the
Willamette River Greenway.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 15:
Finding 17: As noted by the applicant, the subject property is not located within the
Willamette River Greenway. Goal 15 does not apply to the subject Refinement Plan
and Zoning Map Amendment applications.
LRP2007-000/3 & ZON2007-000/2
/9
4-19
APPLICANT'S NARRATIVE RELATED TO GOALS 16-19:
Goal 16 through 19: (Estuarine Resources, Coastal Shorelands, Beaches and Dunes,
and Ocean Resources):
The coastal goals are not applicable to this application,
STAFFS FINDINGS RELATED TO COMPLIANCE WITH GOALS 16-19:
Finding 18: As noted by the applicant, the subject site is not located within any
coastal, ocean, estuarine, or beach and dune resources related area. Goals 16--19 do
not apply to these Refinement Plan and Zoning Map Amendment applications.
CRITERIA OF APPROVAL -- SDC 7,070 (3)(b)
APPLICANT'S NARRATIVE RELATED TO SDC 7,070(3)(b):
The application requests amendment of the Metro Plan diagram from LMI to CC for
approximately 5.24 acres. This section of the application narrative addresses the
. consistency of the amendment with the applicable policies of the Metro Plan,to
demonstrate that adoptioilof the amendment will not make the Metro Plan internally
inconsistent (as required by the approval criteria in SDC 7.070(3)(b)) .
I
This narrative only addresses those policies that apply to the proposal, and does not
discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside
of the urban growth boundary, (2) apply to land uses.other than the current or proposed
designations for the site and will not be affe'c.ted by the proposed Plan diagram and text
amendments, or (3)clearly apply only to specific development applications (e.g" site plan
review submittals or subdivisions). In many instances the goals, policies and
implementation measures apply to specific development proposals that will be addressed
through compliance with applicable City regulations during site plan review of a given
future development proposal.
The Metro Plan Introduction; Section D provides the following definitions:
.A goal as a broad statement of philosophy that describes the hopes of the
people of the community for the future of the community, A goal may never be
completely attainable, but is used as a point to strive for.
An objective is an attainable target that the community attempts to reach in
striving to meet a goal. An objective may also be considered as an
intermediate point that will help fulfill the overall goal.
A policy is a statement adopted as part of the Plan to provide a consistent
course of action moving the community towards attainment of its goals,
Except for the Growth Management Goals, which are addressed below, each of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan.
Metro Plan Elements
1., Growth Management
LRP2007-000/3 & ZON2007-000/2
20
4-?O
Policies
1. The urban growth boundary and sequential development shall continue to be
implemented as an essential means to achieve compact urban growth. Provision of all
urban services shall be concentrated inside the urban growth boundary.
The proposed amendments satisfy this policy because the subject property is inside the
UGB and city limits and as such, encourages compact urban growth. Also, urban services
are available at sufficient levels to accommodate the existing and future infill development
resulting approval of from this' application, The City's site plan ~eview processes ensure
that the appropriate level of services .is available to serve future development.
2, Residential Land Use and Housing Element
Policies
A.11 Genenilly locate higher density residential dev~lopment near employment or
commercial services, in proximity to major transportation systems or within
transportation-efficient nodes.
The proposed redesignation does not affect the inventory or availability of residentially
designated or zoned land, including the single-family residential area abutting Tax Lot 400
that is zoned and designated for Medium Density Residential, or higher density residential
developments located east ofthe site along Main'Street, ,
!
However, approval of the requested redesignation to Community Commercial would allow
for residential areasproximate to the subject area to have close and efficient access to
existing commercial services on Tax Lot 402 and to future medical facilities proposed for
Tax Lot 400, consistent with the above policy. The areas proposed for redesignation offer
existing and future employment opportunities and provide commercial services along a
major transportation system that can support the needs of nearby residential
development.
A.22 Expand opportunities for a mix of uses in newly developing areas and existing
neighborhoods through local zoning and development regulations.
The map amendment and concurrently proposed zone change will allow for existing
commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid-
and east-Springfield area, and for future clinical facilities to be developed to serve this
rapidly growing area of the community, ApproviJlg the requested redesignation and zone
change would expand commercial opportunities to serve these neighborhoods consistent
with the above policy.
3, Economic Element
Policies
,B.1 Demonstrate a positive interest in existing and new industries, espeCially those ,
providing above-above wage and salary levels, and increased variety of job opportunities,
a rise in the standard of living, and utilization of our existing comparative advantage in the
level of education and skill of the resident labor force,
The proposed amendment is consistent with this policy because it will allow medical clinic
uses to be developed to serve growing areas in east and south Springfield. As is '
observed in the Springfield Commercial Lands Study (pp. 27, 29), employment in health
services is growing and approving the requested redesignation will enable increased job.
LRP2007-000/3 & ZON2007-000/2
2/
4-21
opportunities with, higher than average wages thereby helping raise the standard of living
and meet the needs of Springfield citizens, consistent with the above policy.
B.2 Encourage economic development which utilizes local and imported capital,
entrepreneurial skills, and the resident laborJorce,
The construction of and the use of commercial and medical uses will utilize both local and
imported capital and will employ the local labor force in a variety of skilled, semi-skilled,
and unskilled positions, consistent with this policy.
B.6 Increase the amount of undeveloped land zoned for light industry and commercial
uses correlating the effective supply in terms of suitability and availability with the
projections of demand, .
The proposal will add approximately 5.24 acres of Community Commercial land,
consistentwith recommendations to increase the co,mmerciallands inven~ory made in the
Springfield Commercial Lands Study. The SCLS and acknowledged metropolitan
Industrial Lands Study concluded that there is a deficit of needed commercial land, and a
surplus of industrially zoned and designated land. Approval of the requested
redesignation will not cause the inventory of needed industrial land to go into a deficit, but
in fact would, consistent with the above policy, The proposal correlates the need and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopted SCLS.
8.11 Encourage economic activities which strengthen the metropolitan area's position as
a regional distribution, trade, health, and service center. ,-
The amendment will facilitate the development of medical uses that will serve the needs of
the growing residential areas in east, south and southeast Springfield, and strengthen the
metropolitan area's position as a premier locale for healthcare services, consistent with
this policy objective.
6. Environmental Design Element
Policies
E. 1 In order to promote the greatest possible degree of diversity, a broad variety of
commercial, residential, and recreational land uses shall be encouraged when consistent
with other planning policies.
Approval of the proposed map amendments will add just over 5 acres into the City's
inventory of commercially designated'and zoned land, thereby allowing for a variety of
needed commercial uses to occur on the subject property.- Long-standing existing
commercial services on Tax Lot 402 w.ould be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with medical
services that will serve the needs of the growing residential areas east and south of the
subject site, consistent with the above policy,
7. Transportation Element
Land Use Policies
F.3 Provide for transit-supportive land use patterns and development, including higher
intensity, transit-oriented development along major transit corridors and near transit
stations; medium- and high-density residential development within one-quarter mile of
transit stations, major transit corridors, employment centers, and downtown areas; and
/.1'J'2007-000/3 & ZON2007-000/2
22
4-??
d~velopment and redevelopment in designated areas that are or could be well served by
existing or planned transit.
The proposed map amendment and concurrent zone change will enable land use patterns
and development consistent with the abov~ policy. Approval of the proposal will allow for
higher intensity development along Main Street, a major transit corridor. An existing L TO
stop is located on the frontage of Tax Lot 400 (see photo, pg. 2, Appendix A of the TIA),
and will provide convenient access to existing and projected employment on the subject
site, as well as access for patients to future out-patient medical facilities projected on Tax
Lot 400,
Transportation System Improvements: Roadways Policies
F.1S Motor vehicle level of se.rvice policy:
a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on the roadway system, These standards
shall be used for: . - .
, (1) Identifying capacity deficiencies on the roadway system.
(2) Evaluating the impacts on roadways of amendments to'
transportation plans, acknowledged comprehensive plans and
land-use regulations, pursuant to the TPR (OAR 660-012-0060).
(3) Evaluating development applications for consistency with the land-
'use regulations of the' applicable local government jurisdiction.
b. ' Acceptable and reliable performance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CA TS) area, and LOS
D elsewhere,
c. Performance standards from the OHP shall be applied on state
, facilities in the Eugene-Springfield metropolitan area.
In some cases, the level of service may be substandard. The local government
jurisdiction may find that transportation system improvements to bring performance
up to standard within the planning horizon may not be feasible, and safety will not be
compromised, and broader community goals would be better served by allowing a
substandard level of service. The limitation on the feasibility of a transportation
system improvement may arise from severe constraints, including but not limited to
environmental conditions, lack of public agency financial resources, or land use
constraint factors. It is not the intent of TSI Raodway Policy #2: Motor Vehicle Level
of Service to require deferral of development in such cases. The intent is to defer
motor vehicle capacity increasing transportation improvements until existing
constraints can be overcome.or develop an alternative mix of strategies (such as:
land use measures, TDM, short-term safety improvements) to address the problem.
Subsection a.(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR). The accompanying Traffic Impact Analysis
provides the factua,l basis to determine that the proposed redesignation would not result
in a "significant effect" as defined under the TPR (OAR 660-012-0060(1)),
r
Specifically, the proposal does not change the functional classification of Main Street or
any other nearby roadway, and it does not change the standards for implementing the
City's functional c1assificatio'n system of roadways, as identified in the Regional
Transportation Plan. As demonstrated in the TIA, the proposal also does not:'
. Result'in'types or levels of traffic or access that are inconsistent with the
functional classification of Main Street or any other nearby roadway;
lRP2007-000/3 & ZON2007-000/2
23
---.l
4;;;?'l
. Reduce performance of traffic on Main Street or other aIfected
intersections to a level that is below acceptable established performance
standards; or
. Make performance of existing facilities worse (i.e" below acceptable
. mobility standards) than would beJhe case other uses permitted under
existing designations or zoning.
Specific TPR findings are.further located in the TIA, see pp. 31.32, Because the proposal
does not result in a "significant effect" as established by applicable OARs, no further TPR
analysis is required, The request is therefore consistent with the abpve policy.
8. Public Facilities and Service Element
G.1 Extend the minimum leve/ and full range of key urban facilities and services in an
orderly and efficient manner consistent with the growth management policies in
Chapter II-B, relevant policies in this chapter and other Metro Plan. policies.
. . . -
The subject property is located in Springfield's city limits UGB. All necessary
infrastructure and key urban facilities/services are present to serve existing development
(Tax Lot 402) or are available to serve future infill development on Tax Lot 400, Therefore,
the proposal is consistent with the' above policy.
9, Parks and Recreation Facilities Element Policies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment, ,
10, Historic Preservation Element Policies
, Policies in this element of the Metro Plan are notrelevant to the requested diagram
amendment.
11. Energy Element Policies
PoliCies in this element of the Metro Plan are notrelevant to the requested diagram
, amendment,
STAFFS FINDINGS RELATED TO SDe 7,070(3)(b):
Finding 19: The requirement of this criterion that adoption of these proposed
applications not make the Metro Plan internally inconsistent does not mean that every
goal, objective, finding and policy of the Metro Plan must support these applications.
Because of recognized conflicts in the Metro Plan, the proper i'nquiry is whether on '
balance the most relevant of the Plan polices support the Metro Plan Diagram
Amendment. The applicant's narrative discusses numerous Metro Plan Policies and
Elements related to the proposal.
Staff has reviewed the applicant's choice of applicable Metro Plan Policies and Elements
and concur that the noted Policies and Elements are applicable to the proposal. Findings
addressed regarding Goai 9 and Goal 12 in this report also support the stated Metro
Plan policies, Specifically, as conditioned in this report related to Goal 12 compliance,
the Metro Plan Transportation Element and Tra'nsportation Policy F.15 are. satisfied,
LRP2007-0DD/3 & ZON2D07-000/2
24
L~A
The stated Policies and Elements have been .reviewed by staff and are found to be
applicable and consistent with the proposal.
REFINEMENTPLAN MAP AMENDMENT
CRITERIA OF APPROVAL - SDC 8.030 et seq.
In reaching a decision on these actions, the Planning Commission and the City
Council shall adopt findings which demonstrate conformance to the following:
(1) The Metro Plan;
(2) Applicable State statutes.
(3) Applicable State-wide Planning Goals and Administrative Rules.
, '
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC,B.030 (1)-(3):
Finding 20: SOC 8.030(1 )-(3) indicates that a Refinement Plan Amendment must be
consistent with (1) The Metro Plan (2) Applicable State Statues; and (3) Applicable
Statewide Planning Goals and Administrative R\lles. Each of these criteria are
addressed in this report as part of the Metro Plan Amendment Criteria' and the Zoning
Map Amendment Criteria. As noted in the applicant's narrative, SOC 7.110(4) states:
"When a Metro Plan amendment is enacted that requires an amendment to a refinement
plan or functional plan diagram or map for consistency, the Metro Plan diagram
amendment automatically amends the refinement plan or functional plan diagram or map
if no amendment to the refinement plan or functional plan text is involved..." '
There is no refinement plan text amendment proposed as part of this application,
Therefore, no separate refinement plan application is required. As stated in the above
referenced section of the SOC, the refinement plan is automatically amended upon
approval of the Metro ,Plan amendment.
The applicant's narrative related to consistency with specific refinement plan policies is
most, appropriately addressed as part of the Zoning Map Amendment criteria, later in this
report. '
METRO PLAN MAP & REFiNEMENT PLAN AMENDMENT (LRP2007-00013)
CONCLUSION AND RECOMMENDATION
Staff finds that the request meets the criteria of SDC 7.030(a) - (b) and SDC 8.030.
Upon review of the evidence provided by. the applicant, site visits, existing
structures/uses and review of the applicable criteria of approval, staff finds that' the
applicant's request for a Metro Plan & Refinement Plan Map Amendment is appropriate
for the subject property with the following recommended condition of approval:
1. Trip. generation from development' on the subject property shall be limited to a
maximum of 243 PM Peak-hour vehicle trips, which is based on a "reasonable worse
case development scenario" under the existing zoning (LMI) as submitted by the
applicant in the Traffic Impact Analysis for the subject property.
LRP2007-000/3 & ZON2007-000/2
25
4-?~
ZONING MAP AMENDMENT
CRITERIA OF APPROVAL - SDC 12.030 et seq.
SDC 12.030 (1) - Quasi"judicial Zoning Map Amendments - The Planning Commission or
Hearings Official may approve, approve with conditions or deny a quasi-judicial Zoning Map
amendment based upon approval criteria (3)(a)-(c) below. The Planning Commission or Hearings
Official shall make the final local decision on all quasi-judicial Zoning map amendments that do
not incfude a Metro Plan diagram amendment.
SDC 12.030(3) Zoning Map amendment criteria of approval:
(a) Consistency with applicable Metro Plan policies and the Meiro Plan diagram
(b) Consistency With applicable Refinement Plans, Plan Djstrict maps, Conceptual
Development Plans' and functional plans; and
(c) The property is presently provided with adequate public facilities, services and
transportation networks to support the use, or these facilities, services and transportation
networks are planned to be provided concurrently with the development of the property.
NOTE FROM STAFF REGARDING APPLICANT'S ZONING MAP AMENDMENT,
NARRA T1VE: The applicant's narrative for the Zoning Map Amendment is similar
to the narrative for the Metro Plan & Refinement Plan Amendment, addressing
many of the same criteria: The portion of the Applicant's Narrative related to
Refinement Plan policies is included below, Rather than be duplicative in this
report, and for ease of review, Staff has attached the remaining portions of the
applicant's written narrative in its entirety for reference,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(a):
Finding 21: This criterion is also found in SDC Section 7.070(b) under the Metro Plan
Amendment criteria. Specific findings related to compliance with Metro Plan policies and
the Metro. Plan diagram has been addressed in this report. The applicant is proposing a
Metro Plan Map Amendment as part of this application from LMI to Commercial. Upon
approval of the Metro Plan Amendment application (LRP2007 -00013), the proposed
zone change will be consistent with the Metro Plan diagram.
. Conclusion: The proposed rezone request is consistent with Metro Plan policies and
the Metro Plan Diagram,
APPLlCANT'~ NARRA'TIVE RELATED TO COMPliANCE WITHSDC 12,030(3)(b):
The following demonstrates how the proposal is consistent with applicable policies in
the East Main Refinement Plan (EMRP).
1. Mixed-Use Element
LRP2007-000/3 & lON2007-00011
16
A_I)C
Policy 2) Area #2
A) The following land uses are allowed under Community Commercial zoning:
All Communit~ Commercial uses subject to Article 18 of the Springfield
Development Code.
The proposal requests redesignating the subject properties to Community
Commercial, and concurrently rezoning the properties to CC, as is allowed by the
above policy and consistent with other EMRP policies. Approval of the request would
allow long-standing existing commercial uses on Tax Lot 402 to continue as permitted
under Article 18, and consistent with neighboring uses to the west and south, which
are also zoned and designated for commercial uses,
2, Commercial Element
Criteria for Commercial Refinement Plan 'Desicmation
1. Generally, the Community Commercial refinement plan designation shall be
applied under the following circumstances:
A) where it is not an intrusion into well-maintained residential
_ neighborhoods; ,
,The proposed redesignation does not intrude into the existing residential area west of
the subject site along 44th Street, and is therefore consistent with the above criterion,
B) where it does not increase conflict between Low Density Residential
and Commercial;
Although the abutting residential area is zoned Medium Density Residential, it is
developed in low density residential uses. Approval of the proPC!sed redesignation of
the subject sites would actually result in a decrease of conflicts between abutting
residential and non-residential land uses by allowing future infill development on Tax
Lot 400, and through the site plan review process establishing improved landscaped
'buffers and a use more compatible than. the industrial uses that historically abutting
this residential area,
C) where criteria for designating Medium Density Residential land does
not apply;
Criteria for designating MDR land does not apply to the subject site,
D) where legally created commercial uses exist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP,
E) where adequate customer and service access to an arterial street can
. be provided; ... and
The subject site has,adequate legal access onto Main Street, which is classified as an
arterial'street. "
LRP2007-000/3 & ZON2007-000/2
27
A_?~
F) where designated Commercial on the Metro Plan Diagram.
Approval of this application would result in a Commercial designation on the Metro
Plan diagram, which would also automatically modify th.e designation on the EMRP
diagram,
Policy 2) Apply site-specific Commercial refinement plan designations to clearly define,
the limits of new commercial uses where there is not an existing, legally established, and
beneficial mixing of uses,
Approval of the requested redesignation would apply Commercial plan designations to
the subject properties, allowing the existing, legally established commercial uses on
Tax Lot 402 to continue. It.would also enable commercial uses to be established on
Tax Lot 400, thereby defining'the limits of new commercial uses between the pre-
existing commercial uses on Tax Lot 402 and others to the west, and the developed
industrial business park to the east, Tax Lot 400 does not have an existing or
beneficial mix of uses, but has historically housed industrial yard-type operations.
Therefore, approval of the proposal would define the limits of new commercial uses as
called for in the above policy, and also provide the ability to make superior buffering
and other improvements associated with future development on Tax Lot 400 through
the site plan review process.
Policy 3) Reduce the number of vehicular access points and require the rebuilding of
curbs and installation of sidewalks and street trees along Main Street, through the Site
Plan Review process and in public improvement projects,
The proposal would result in reducing the number of existing access points as
required above, Through the Site Plan Review process, future development on Tax Lot
400 will have a single driveway access onto Main Street, eliminating one of the two
existing curb cuts on this site. Sidewalks and street trees are already located along its
Main Street frontage, consistent with the above policy.
. Policy 4) Provide buffering between commercial ,and residential uses through Article 31 of
the Springfield Development Code, Site Plan Review process.
Existing residential uses along the east side' of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would allow for
attractive infill development of future medical facilities that would provide (through the
SPR process) improved landscaped buffers between the future use and existing
residential area to the west - as required by Code, and consistent with the above
policy.
3, Industrial Element
Policy 1) The City shall encourage efforts of various agencies to attract new and retain
existing jobs and businesses. '
Imolementation
The City shall maintain a current inventory of vacant commercial and industrial land and
structures within the East Main area.
Consistent with the above policy, approval of the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal,
conforming land uses, and allow future development of new employment on Tax Lot
..
LRP2007-000/3 & ZON2007.{)OO/2
28
1-?g
~
400 with higher than average wages and employment densities than the current
designation and zoning allows.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(b):
Finding 22: As previously mentioned in this report, the subject property is located within
the East Main Street Refinement Plan area, The applicant's narrative above discusses
refinement plan Elements and Policies,
Finding 23: The applicant references policies in the Mixed Use Element, Area 2. This
area (Area 2) is located south of the subject property (across Main Street), and is not
part of the subject property. Reference to this polity is not applicable to this application.
Finding 24: The applicant discusses specific criteria listed in the refinement plan for
commercial and industrial uses, Staff concurs with the applicant's narrative related to the
commercial criteria.
Finding 25: Criteria of approval for consistency with all applicable City of Springfield
functional plans havel:ieen previously addressed in this report. As noted in the findings
in this repo~, the proposal is in compliance with all applicable functional plans,
, Conclusion: Based on the above findings, the proposed zone change is in compliance
with SDC 12.030 (2).
STAFF'S FINDINGS RELATED TO COMPLlANC~ WITH SDC 12,030(3)(c):
Finding 26: As previously noted in this report and as stated by the applicant, the subject
properties are currently served by sanitary sewer systems and storm drain systems
Springfield Utility Board (SUB) has sufficient capacity to provide electrical and water
service to the site.
Finding 27: The property is served by Springfield Fire and Life Safety,
Finding 28: The site is within Springfield School District 19.
Finding 29: The site is within the Willamalane P<;1rks and Recreation District.
Finding 30: Transportation systems currently provide access to the property. The
subject site takes access from 44th Street which is under City of Springfield jurisdiction
and Main Street, which is under ODOT jurisdiction.
Finding 31: The proposed zone change is from LMI to CC. The subject lot has existing
development on all sides, and is located on 18th and Main Street. As previously
discussed in findings in this report, and as conditioned, the proposed zone change will
not significantly affect the existing transportation network. The proposed zone change
will not negatively affect existing public transit service.
I
LRP2007-000 /3 & ZON2007-000 /2
29
d-?Q
Finding 32: Solid waste management service is available at the subject property. The
City and Sanipac have an exclusive franchise arrangementfor garbage service inside
the city limits.
Finding 33: The site receives police protection from the City of Springfield, consistent
with service provision throughout the city and with service that is now provided to
adjacent properties.
Finding 34: The City of Springfield Development Services Department provides larid
use control for property within the City's jurisdiction.'
Finding 35: Qwest and Comcast currently provide telephone and cable communication
service in this area for and an array of wireless companies provide a number of different
communication services. The City has no exclusive franchise arrangements with
telecommunication or wireless companies, The field is competitive and therefore'
guarantees a wide selection currently.
Conclusion: All key urban facilities and services required for the proposed re:;;:one are
available to the site, Any specific public and private improvement requirements and
utility connection points will be determined when the property is developed. The proposal
meets 12.030(3)(c),
ZONING MAP AMENDMENT CONDTIONS OF APPROVAL:
SDC12.040
SDC Article 12 allows for the Approval Authority to attach conditions of approval to a
Zone Change request to ensure that the application fully meets the criteria of approval.
The specific language from the code section is listed below:'
12,040 Conditions of Approval
The Approval Authority may attach conditions as may be reasonable necessary in order
to allow the Zoning Map amendment to be granted.
Staff have reviewed the Zone Change request and supporting information provided by
the applicant and do not recommend any conditions of approval other than the condition
already stated for the Metro Plan I Refinement Plan Map Amendment related to trip cap
require~ents.
The Planning Commission may choose to apply conditions of approval as necessary to
comply with the Zone Change criteria.
LRPi007-000/3 & ZON1007-000/1 ,
30
d-'ln
, ZONING MAP AMENDMENT (ZON2007-00012) CONCLUSION AND
RECOMMENDATION
Staff finds that the request meets the criteria of SDC 12.030. Upon review of the
evidence provided by the applicant, site visits, existing structures/uses and review of the
applicable cdteria of approval, staff finds that the applicant's request fora zone change
from LMI to CC is appropriate for the subject property and recommends the Planning
Commission approve the attached Order and forward the proposed Zoning Map
Amendment Application ZON2007-00012 to the City Council with a recommendation for
adoption.
LRP2007-000/3 & ZON2007-00012
31
~_11
~
EXHIBIT A-1
.
5.0 TRIP GENERATION AND DISTRIBUTION
5.0 TRIP GENERATION
To determine the traftic impacts of a development on a roadway system, the number of
vehicle movements resulting from the development must be estimated: These
movements are referred to as "trips", Trip generation is the estimated volume of trips
, resulting from the development. '
The amount of trips expected to be generated by thepropgseddevelopment was
determined using the information contained in the ITE Trio Generation Manual, 7th
Edition. The equations in the mailUal predict the number 'of trips generated based on the
gross square feet oj' floor area. Separate trip generation analyses were performed for the
. .' --
AM and PM peak hours for the development.
, Under the current Light-Medium Industrial zoning thedevelopment site can be built out
to include a variety of land uses specified in Springfield Development Code Article 20.
The maximum trip generation of the development was det_ermined for the allowed land
, uses under the current zoning, Tables 5 and 6 illustrate the maximum development
potential and subsequently the maximum trips generated by the development site using
the following ITE Land Use Codes: '
i
.: i
. Land Use Code 760 - Research and Development
. Land Use Code 714 - Corporate Headquarters'
. . Land Use Code 492 - Health/Fitness Club
. Land Use Code .5 65 - Daycare Center
'Research and
Development,
'760 '; 80 Ln(T)=0.8S'Ln(x)t0,88" 114,0,83.0.17 ,":95 ,..1.9'
". ;,~-.-
. . ., . . .
, '
'-07~l~~~d.~~tiiJ1J.~~~j.i}il~~ifI'":~"" '.'
Health Fitness Club -
492
4
, T=1.21'x
, 5
0,42 0.58' '2
, ,
3 ,
Total Trips 229
168 61
JRH TRANSPORTATION ENGINEERING I East S~i!:~ftld Rezone - Springfield, Oregon I March 6, 2007118
.
Table 6: PM Peak Hour Trip Generation-Maximum Potential of Site for Existing Zoning
~, ~~. J
Research and'
Development'
Ln(T)=O,83'Ln(x)+t06 110' 0,15 0,850,16: 93'
. 760
80
'Health Fitness Club
,-" 8,}1!26~G'~ ik1i\fil(Jj;O:875"
i~:t;.j~.t'~;i~:;~'~m ~i~!~{[i,:;,~)<ijtht-\:O"~~ .
hr:-;~~"r t!<'.. .'~"1'fL\~t~'_'IKoW""'I' ,I
,,~~i.~];~~r~~~" &'kif~~1ffi&1-~4~
. , 492 4, '.' T=4,05'x .'
........
With the zone change the development site will be built to include an approximately
30,000 square foot medical otIice,building. The land bse code for a fully developed
" medical otIice building was 720 - Medical-Dental Office Building. This was used in.
place of Land Use Code 630 - Medical Clinic because, after close inspection of the Trip
, Generation Manual. it was determined that the sample size for this category of land use
vias too small to create a reliable estimate of trips generated. Table 7 illustrates the traffic
generated by the proposed 30,000 square foot medical office building, Tax Lot 402 is
currently occupied by a coinmerciallspecialty retail center. With the proposed zone,
change, the building will remain on the property and will continue to operate as a
specialty retail center. Vehicle trips using this site have already been accounted for on the
roadway in the backgrolmd traffic volumes; therefore, no new development trips, were
assigned to this Tax Lot. '
Table 7: Peak Hour Trio Generation-Medical Office Building
.. i?'ra.:t} (.:r."<
~':l~~~M~~fl~i,11~j~~!;\Oi~~ ~:5~~~,r:~
AM
T=2.48'x
74 79% 21% 58
~t~~J:~.0Jil~Q4tl;:42j~I~~itiJ!~{~ :ij~ I!~%,:;ll~;i~;~
There are 155 fewer AM and 140 fewer PM vehicle trips generated by the medical office
building when compared to the maximum potential of the site under the current zoning.
JRH TRANSPORTATION ENGINEERING I East Springfield Rezone - Springfield, Oregan I March 6, 20071 ,19
4-33
EXHIBIT A-2
16
.
5.1 TRIP DISTR.IBUTION AND ASSIGNMENT
After determining the trip generation, the next step in the analysis requires distributing
and assigning the trips to the,existing traffic network, Trip distribution allocates the trips
generated from the developments to generalized destinations. Trip assignment routes
trips to these generalized destinations via the actual street network, The trip distribution
,for this project was based on the existing distribution pattern of the study an~a roadway
network, where applicable. Access to Tax Lot 400 is assumed to be limitedto a single
full-movement access from Main Street. Figures 9 and 10 shows the assigned vehicle
trips generated by the 30,000 square foot medical office building for the AM and PM
peak period respectively.
5,2 BUILD TRAFFIC VOLUMES
To determine the Build 1ranic volumes the development trips assigned' throughout the
study area were added to the background tranic data, The year 2008 AM and PM Build.
year traffic volumes are illustrated in Figures II and 12, respectively, The year 2023 AM
and PM Build year traffic volumes are illustrated in Figures 13 and 14, respectively
J,
JltH TRANSPORTATION ENGINEERING I East Springfield Rezone - Springfield, Oregon I March 6,2007120
4-34 '
EXHIBIT A-3
I
1
!
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I
,
J,
I
,
;
i
,
!
I
,
I
I
I
I
L'
i
I
'1
I
7.0 TPR FINDINGS.
I
I
Tne follo~ving discllsses the Oregon Administrative Ruling 660-012-0000, the
Transportation Plaffiling Rule, and the effect ofthe proposed development on the,
transpOltation facilities as it applies to the ruling.
660-012-0060
I
Plan aud Land Use Regulation Amendments
I
. (l)}Vhere an' amendment to afunctional plan, an acknowledged comprehensive plan, or
'a land !/se regulation would significantly affect an existing or planned transportation
,facility, the locafgovernment shall put in place measL/res as provided in seCtion (2) of
this rule to assure that allowed land uses are consistent with the identified function,
capacity, and performance standards (e,g. level of service, volume'to ~apacity ratio,.etc)
of the facility. A plan 'or land use regulation amendment significantly affects a '
transportation facility if it lvould:
(a/Change the fi/llctio~al classification of an existing or planned transportation facility
(exclusive of correction of map errors in an adopted plan);
. The addition of development traffic on the adjacent roadways does not cause the
change in functional classification of any of the transportation facilities.
(b) Change standards implementing afimctional classification system; or
I
I
I
I
I
I
The standards implementing a functional classification system within the project
study area are not changed by the proposed development
(c) As measured at the end of the planning period identified in the adopted transportation
system plan:
I
I
I
(B) Reduce the performance. of an existing or planned transportation facility below the
minimum acceptable performance standard identified in the TS? or comprehensive plan,
or
The addition of development traffic does not reduce the performimce of an
existing or planned transportation facility below the minimum acceptable
performance standard.
JRH TRANSPORTATION ENGINEERING I East Springfield Rezone - Springfield, Oregon 1 March 6,2007131
4-35' .
.
!iJ
EXHIBIT A-5 ]
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(C) Worsen the performance of an existing or planned transportation facility' that is
otherwise projected toper form below the minimum acceptable pelformance standard
identified in the TSf or comprehensive plan.
The addition of development traffic does not further degrade the perfom1ance of
intersections, projected to perform below the minimum acceptable performance
standard.
As shown, the proposed redesignation of Tax Lot 400 and 402 does not result in a
"signiticant effect" on the transportation facilities as defined i,n the TPR. '
8.0 SUMMARY AND RECOMMENDATIONS
This report provides an analysis of potential traffic impacts resulting from the proposed
redesignationlzone change and future development of the subject site in Springfield,
Oregon, This development will include approximately 30,000 square feet of medical
office space, The parcel proposed for development is located east of 44th Street and west
of 48th Street on Main Street. A single unsignalized full-movement. access point on Tax
Lot 400 and existing driveway access to Tax Lot 402 is assumed.
Completion of the proposed development is anticipated for the year 2008, This report
includes year of completion analysis, year 2008, for the roadway network within the
study area, In addition, a horizon year analysis was performed for the year 2023.
A performance analysis was completed for the intersections of Main Street and 42nd
Street, Main Street and 48th Street; Main Street at 44th Street; and Main Street at 46th
Street. The operational analysis of all intersections within the study area shows that
under the Build condition no degradation in volume-to-capacity ratio in comparison to
the No-Build condition occurs due to' the additional trips producep by this development.
All study areas meet the mobility standard for the Build condition.
-
A queuing analysis was performed for the intersection within the study area. The queuing
analysis, which assumes the current lane contiguration throughout the planning horizon,
was performed to determine the amount of required storage length due to the construction
of the project. The results of the queuinganalysis indicate that all existing storage lengths
. will facilitate the queuing anticipated for the traffic demand, including the proposed
development. .
According to the Ending under Oregon Administmtive Ruling 660-012-0000, the
Transportation Plaffiling Rule, the proposed redesignation of Tax Lot 400 and 402 does
not result in a "signiEcant etTect" on the transportation facilities as defined in the TPR.
JR.H TAANSPOR.TATION ENGINEER.1NG I East Springfield Rezone - Springfield, Oregon I Marcn6, 2007 132
4-36
EXHIBIT A-6
, Memorandum
City of Springfield
Date: . April 4, 2007
To: David Reesor, Planner III
From: Gary McKenney, P.E., Transportation Planning Engineer
Subject: LRP2007-000l2 PeaceHealth PAPA
The following comments and recommendations are based on my preliminary review of the
assumptions used in the traffic analysis report (TIA) and other materials provided with the
subject application. Pertinent pages of the TIA are attached for reference,
Traffic Impacts Analysis
In estimating the trip-making potential of site development under existing LMI
designation/zoning the TIA assume the land uses as depicted in Table 5 (Page 18).
Rec()mmel1dation: Confirm that the uses assumed in the "existing-designation" ,
development scenario are permitted, and that they represent a "reasonable worst case." .
In estimating the trip-making potential of site development under proposed CC
designation/zoning the TIA assumed a single land use (Medical Office Building) as depicted in
Table 7 (Page 19).
Recommendation: Confirm that the use assumed in the "proposed-designation"
development scenario represents a "reasonable worst case." If not, we need to decide
whether limiting allowed development to the level assumed in the TIA would be an
acceptable means of ensuring that future development would not generate traffic in
excess of what is estimated in the, TIA. If we find that the assumed Medical Office use
would under-utilize the land, then we will want the TIA revised to reflect the impact of a
true "reasonable worst case."
Goal 12 TPR AnalysislFindings
The PAPA application refers to the Goal 12 findings contained in the TIA. These are presented
on pages 31 and 32. The validity 6fthese fmds will depend on the details of the technical'
analysis and supporting assumptions,
4..,37
Page 1 of 1
EXHIBIT A-7
REESOR David
From: MCKENNEY Gary
Sent: Thursday, April 05, 2007 9:23 AM
, To: REESOR David
Subject: PeaceHeallh PAPA Traffic Analysis
Follow Up Flag: Follow up
Flag Status: Red
David,
In considering what a "reasonable worst case" development scenario might be for the re'zoned condition
it is clear that a 30 KSF Medical Office Building is much less intense than other uses that would be
permitted in the CC zone. On a per-square-foot basis the MO is estimated to generate 2.47 vehicle
tips/l,OOO SF and 3.43 vehicle tips/l,OOO SF during the AM and PM peak hours respectively. For
comparison the average rates for a "Fast-Food Restaurant with Drive-Through Window" are 53.11
vehicle tipsll,OOO SF arid 34.64 vehicle tips/I ,000 SF,
In considering the Goal 12 "insurance policy" issue some mord thought of another possible way to deal
with it, which we did not discuss yesterday. We might choose to limit the trip generation for the
rezoned land to be no greater than what,would be expected from development under a reasonable worst
case with existing zoning.
I'd like to discuss these ideas further in our meeting with Ed Moore.
Gary
4-38
5/25/2007
.' - ~ ,-,-_.~"","~ '.'.
" 'E3tRisftA-s'
-Oregon
Theodore R. Kulon9oski, Governor
DATE:
May 10, 2007
Department of Transportation
"Region 2 Tech Center
455 Airport Road SEBuildin9 A
Salem,Ore90n 97301-5397
Telephone (503) ,986-2990
. Fax (50'3) 986-2839
File: T15-2
TO: Ed Moore
Area 5 - Senior Planner
FROM: ' Stephen B. Wilson, PE
, , Region 2 Senior Traffic Analys
SUBJECT: East Springfield Rezone
Traffic Impact Analysis Review
Highland Business Park - Peacehealth Medical Office Buildfng'
McKenzie Highway - 'OR 126 Bus. (Highway #15)
Milepost 4.61- 5,00
City of Springfield
Lane County
These are review comments for the East Spritigfie1d Rezone Traffic ImpacfAn:alysis (rIA), prepared by
JRH Transportation Engineers. The focus of this review is the analysis methodologies and assumptions,
The results and conclusions of this study are in question, due to noted inconsistencies, It,is'recommended'
this study be revised,' taking into ,accouht these comments. Region 2 Trajfic .will need to ,review any
revised traffic study, to ensure it complies with ODOT requirements, before,is,can b~ deemed acceptable.'
Page I.:, Paral:raph
'7 Table I
8 Seasonal
Adjustment
8 Peak Hours
n.
Figure 4
12 .
Section 3.1
" '
;~~~l:ss;~cation of Main Str~~t~;;ri:26)iPUst also be listed~y~e \
ODOT highwa~ classification, ' . "
This study needs to demonstrate how the Seasonal Adjustment factors
were applied to the raw traffic data. ,A graphic showing .the. raw
traffic volumes should also be included. ' ,
'The peak hours assumed for this study seemreasol1ab1e;. assuming the
'Peak Hour,Factors were calculated off datil from these assumed hours,
and were the same for all intersections. '
The 2006 Existing PM Peak traffic volumeS do not seehtcorrect. As
part of this review, calculations were made 'using the raw traffic data,
and the assumed Seasonal Adjustment factors, presented in this study,
The review calculations were unable to corllirin the traffic volumes
12resented in FiguJ'e 4. See related comment for Pal:e 8.
ODOT does not have a standard from which you can compare an
Intersection Crash Rate, This study cites a ~rash rate threshold of 1.0,
This is not an ODOT .standard; and it is unclear where this standard
may have originated. The only ODOT standard for comparison is a
Segment Crash Rate, which should 'be calculatedfor the crashesin at
least a mile of the study area roadway,
-1 -.
4-39
.Page
l3
, 18
18
19
n/a
nla
Paragraph
Growth Factors
Existing
Zoning Trip
Generation
Table 5
Proposed
Zoning Trip
Geileration
Future
Build-Out
Traffic
Volumes
Section 6,0
nli
Manual Count
Data
nla
S ynchro
Analysis
)\
Section 7,0
EXHIBIT A-9
Comment
This study must demonstrate how the Historical Growth Rates were
applied to the 2006 30'" Highest Hour traffic volumes, Calculations to
confirm the 2008 and 2023 data were unable to duplicate the future
volumes cited in this report.
This report states the maximum development potential was
determined for the property, given its current zoning of Light-Medium,
Industrial, For this scenario, how was the maximum allowable
develo')ment determined?
The trip generation assumptions and output in this table are accurate.
This study's trip generation analysis for the proposed zoning, assumed
a 30,000 sf Medical Office Building would be the only development
on this site, To satisfy the requirements for a TPR-Ievel analysis, the
trip generation study for the propOsed zoning must be for the
maximum allowable ,develoDmen~ on that site, given the City's
development codes and regulations,
The traffic volumes' for all Future Build-Out data sets wiU need to be
revised to account for 601Tections made 'to address the previous
comments, I
The traffic data for this study is in question. Any analysis made from
these data sets is also questionable and must be revised; taking into
account the previous comments, This comment can also be applied to
the cueuing analysis develo')ed for this study,
The scope of work for this TIA requiredJ-hour Manual Classification
Counts for all study-area intersections, However, a review ,of the
manual count data was unable to determine any tlUck volumes or
percentages. The truck traffic in this study area is sign'ificant, and,
must be taken into account
A review of the Synchro output has noted several inconsistencies
throughout the analysis:
. An Ideal Saturation Flow'rate of 1900 pcphpl was assumed
for both signalized intersections (42'" & 48'''), while .1800
pcphpl ";'as assumed for the two unsignalized intersections,
The ODOT Analysis Procedures Manual requires a saturation
flow rate of 1800 pcphpl for aU intersection analysis,
. The truck percentages must be based on real-world data. The
Synchro default of2% is not acceptable. '
. Unless the Yellow Time (s) entered into Synchro for the
signalized intersections is based on either an ODOT or City
timing sheets, this analysis should assume 4.5 seconds of
yellow for the OR 126 approaches, and 4.0 seconds of yellow
for the City-street approaches. The 5.0 seconds of yellow iif
generally reserved for highways with an 85'" Percentile Speed
equal to, or greater than 45 mph. ' .
The TPR findings from this study are in question, due to the
inconsistencies noted in this review. It is very likely they will need to
be' revised, based on the recommendations in this review. J'
- 2-
4-40
"a'E'XHli3fT A-10.
\Page"'%Paragrapli'
32
Section 8,0
Based on .the previous comments in this review, the .conclusions
drawn and recommendations ,proposed are iil question. It is very
likely they will.need to be revised, based on the recommendations in
this review,
If y~u have any questions regarding my comments, please contact me by phone at (503) 986,2857 or by
e-ml;lil at slenhen".b. ~t'ilson(@.od(}{.'itl1te.or.u.\:.
Cc: Jim Hanks - JRH
David Warren
Jane Lee
Mike Spaeth
Dennis Santos
File,
>
- 3-
4-41
FW: Springfield - East Springf-'-1 Rezone TPR Analysis Review
Page lof2
EXHIBIT A-11
REESOR David
From: MCKENNEY Gary
Sent: Tuesday, May 15, 20074:28 PM
To: REESOR David
Subject: RE: Springfield - East Springfield Rezone TPR Analysis Review
Attachments: LRP2007-00012 Trans mem01.DOC
David ---
I believe Steve Wilson is thinking in the context of an unconditioned approval of the PAP AlZC, '
Given the approach we' planned to take in conditioning this approval, I think only Item #18 of his noted
issues is relevant to ensuring Goal 12 compliance.
This issue was discussed in my April 4,2007 memo to you (copy attached), I aSsume you can respond
to Steve's question on how we conclude that the assumed existing-zoning development scenario is no
more intense than "worst case."
If we condition the PAPA to limit trips to less than or equal to what would be generated by the "worst
.case," all the other issues appear moot
"
, Gary
,
-
From: REESOR David,
Sent: Monday, May 14, 2007 10:34 AM
To: MCKENNEY Gary' '
Subject: FW: Springfield - East Springfield Rezone TPR Analysis R7view
Gary-
.......,-"._;
What are your thoughts on the attached memo?
-DR
From: MOORE Ed W [mailto:Ed.W.MOORE@odot.state.or,us]
Sent: Monday, May 14, 2007 8:06 AM
To: REESOR David; MCKENNEY Gary
Subject: fIN: Springfield - East Springfieid Rezone TPR Analysis Review
FYI '
4-42
5/25/2007
, REESOR David
From: MOORE Ed W [Ed'w.MOORE@odot.state.or.us]
Sent: Monday, May 21,20073:14 PM
To: REESOR David
Subject: RE: Peace Health Plan and Zoning MapAmendment
Dave, that is' what we agreed to at our meeting and it still hold for us. Ed
-----Original Message----"
From: REESOR David [mailto:dreesor@cLspringfield.or,us]
Sent; Monday, May 21, 200711:49 AM
To: MOORE Ed W (OR)
Cc: MCKENNEY Gary
Subject: PeaceHealth Plan a.nd Zoning Map Amendment
,Hi Ed-
Page 1 of I.
EXHIBIT A-13
I just wanted to clarify with you ODOT's position on the Peace Health proposal (LRP200Hl0013 &
ZON2007-00012), Based upon the meeting you and l:had with Gary McKenney, we are all in agreement
that the most appropriate way to address Goai 12 compiiance on this proposal is by conditioning a trip
cap to what the worse case scenario wouid be under existing zoning (LMI). Does this 'sound correct to
you? '
Thanks, ,
David Reesor
Planner III
City of Springfield
541.726.3783
4~43
5/25/2007
FW: Springfield - East Springf ' i Rezone TPR AnalY,sis Review
Page 2 of2
EXHIBIT .A-12
--Original Message---
From: WlL5,ON Stephen B
Sent: fMday, May 11, 2.007 10:03 AM
To: MOORE Ed W '
Cc: jimhanks@jrhweb,com; WARREN David; LEE Jane S; SPAETH Michael,A; SANTOS Dennis N
Subject: Springfield - East Springfield ~ezone TPR Analysis Review
Ed,..
This is my technical review of this TIA submitted by JRH. I apologize for the delay in
getting this review out.
<<East Springfield Rezone TPR Analysis Review.pdf>>
, Stepfien fB. Wil6cm, Iff-
Senior Transportation Analys't
ODOT - Region 2 Tech Center
455 Airport Road SE - Building' A' .
Salem, OR 97301-5397
(503) 986-2857
"
4-44
S!?S/2007
11 PeaceHealth
March 15, 2007
Type II Metro Plan/East Main Refinement Plan
, Diagram Amendments
Written Explanation of the Proposal
Applicant:
PeaceHealth Oregon Region
770 E, 11th Avenue
P.O. Box 1479
Eugene, Oregon 97440
Property Owners:
Hyland Business Park, LLC (Tax Lot 400)
1941- A Laura Street
Springfield, OR 97477
Attn: ShaunHyland
(541) 726-8081
Andrew Head (Tax Lot 402)
1616 Ardendale Ln.
Eugene, OR 97405
(541) 521-3403
Applicant's
Representative:
Philip Farrington, AICP
Director, Land Use Planning & Development
PeaceHealth Oregon Region
123 International Way
Springfield, Oregon 97477
(541) 686-3828 * Fax (541) 335-2595
pfarrington@peacehea1th,org
1.0 Land Use Request
. PeaceHea1th Oregon Region (the "Applicant") requests approval to change the' map
desigr>ation on the Metropolitan Area General Plan ("Metro Plan") diagram from Light
, .
Medium Industrial ("LMI") to Community Commercial ("CC") for approximately 5,24
acres identified as Tax Lots 400 and 402 on Assessor's Map No. 17-02-32-00, This same
acreage on the site is being proposed for a concurrent amendment to the Springfield
zoning map from LMI to CC, as allowed in Springfield Development Code ("SDC")
12.020 (l)(a)1.
4-45
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region.
March 15,2007
Page 2
The area subject to the proposed land use designation changes is mapped on Attachment
A, and is referred to collectively in this application as the "subject properties" or "site,"
Pursuant to SDC 7,110 (4), approval of the requested Metro Plan diagram amendment
automatically amends the refmement plan diagram and is processed concurrently.
Findings of fact addressing the criteria of approval in SDC 7.070(3) are included in this
narrative statement (see Section 5 below).
2.0 Project Purpose, Relationship to East Main Refinement Plan
The Applicant seeks to redesigrlate and rezone the subject properties to CC so they may
be developed for commercial uses (i.e., Tax Lot 400), including a possible future medical
, clinic which could serve residents in the growing east Springfield area, and to be allowed
to continue long-standing commercial operations (i.e., Tax Lot 402). Approval of this
land use request would preserve employment and existing viable commercial.operations
on Tax LotA02,and create stable family-wage employment opportunities on Tax Lot 400
_ a vacant and underused industrial site. The proposal would also help b"autify this
portion Of Main Street from its traditional industrial yard uses, and future development
would provide a superior buffer for residential uses to the west than currently exists.
The proposal is also consistent with the East Main Refinement Plan (EMRP) criteria for
designating property as Commercial within the refinement plan (EMRP, pg. 12) since:
a) The proposal would not be an intrusion into a well-maintained residential
neighborhood. The proposaJ'would allow for higher quality development than has
historically existed on the vacant industrial site (Tax Lot 400), therefore providing
opportunity for improved buffering between abutting residential and non-
residential uses. Tax Lot 402 borders only Tax Lot 400 and two commercially
zoned parcels, so legitimizing the pre-existing commercial uses on that property
would not affect the existing residential area nearby.
b) It does not increase conflict between Low Density Residential and Commercial
uses, but in fact can provide for uses and development far superior to those that
have traditionally been located adjacent to the abutting residential area,
Moreover, the area abutting Tax Lot 400 to the west is zoned Medium Density
Residential, though in primarily low density' residential use,
c) The criteria for designating Medium Density Residential land does, not apply
because the subject properties are not currently developed, nor have they ever
been designated, for MDR uses.
d) Legally created commercial uses have existed on the properties, and the proposal
would facilitate higher quality commercial uses (such as medical offices) than
have existed before on Tax Lot 400, and allow for Plan designations and zoning
to correspond with long-standing legally establishedcominercial uses on Tax Lot
402.
e) Adequate access exists to an arterial street, with existing curb cuts directly onto
Main Street.
4-46
. ~
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15,2007
Page 3
f) Upon approval of this request, the site would have a Commercial designation on
the Metro Plan diagram.
The proposal is also corisistent with EMRP Policy 2: "Apply site-specific Commercial
refinement plan designations to clearly define the limits of new commercial uses where
there is not an existing, legally established, and beneficial mixing of uses," (pg. 12) The
proposal to allow for a broader, more beneficial range of commercial and employment-
generating uses on the subject properties. It would also improve the area and better
distinguish and buffer adjacent residential and industrial business park uses.
3.0 Site Context
The subject properties include a vacant, flat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) east of 44th Street along'Main Street in east
Springfield. The site is bordered on the south by Main Street, on the east by the Hyland
Business Park, on the north by an open area south of the Weyerhaeuser mill site (Tax Lot
400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises (e.g., a cabinet shop and karate school) fronting Main
Street and residential homes along 44th Street west of Tax Lot 400, Commercial
enterprises are located immediately south of the site across Main Street (e.g" Gray's
Garden Center).
While historically involved in agricultural uses; since around 1990 Tax Lot 400 was used
as a storage and sales yard for landscape organics and forest by-products, The current
property owners also used the site to store modular constructiori offices, tool trailers,'
construction equipment and concrete form plywood, Tax Lot 402 has had various .
. commercial services on site since the 1950s.
The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic
resources. The site is within the Springfield Urban Growth Boundary, and both parcels
were annexed into the City of Springfield in 1960. The EMRP diagram (adopted in
1988) currently designates the subject property for industrial uses,
The abutting property to the east is designated Light/Medium Industrial in the EMRP
diagranl and zoned LML The areas immediately to the west and south of the site fronting
Main Street are identified as being within Mixed-Use Area #2 in the EMRP, and are all'
zoned Community Commercial. Property to the west of Tax Lot 400 along 44th Street is
zoned and designated Medium Density Residential.
4-47
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 2007
Page 4
4.0 Type II Metro Plan Diagram Amendment
Amendments.to the Metro Plan are classified as Type I or Type II amendments,
depending upon the specific changes sought The proposed Metro Plan and EMRP
amendments are "site specific" and relate to property solely within the corporate limits of
the City of Springfiel~, The Metro Plan defines Type II amendments as: .
,
"[Ajny change to the Plan diagram or Plan text that is site specific
and not'otherwise a Type I category amendment."
The proposed amendment is a Type II site-specific amendment because it:
. Involves a specific geographically identifiable property;
. Does notchange the metropolitan Urban Growth Bou,ndary;
. Does not change the Metro Plan jurisdictional boundary;
. Does not require a goal exception;
. . Does not include a non-site-specific amendment of the Metro Plan text; and
. Applies only to property located within the Springfield City limits.
Accordingly, the current proposal is properly characterized as a Type II amendment (as
defined in SDC 7.030) that must be reviewed and approved by the City of Springfield,
consistent with SDC 7,070 (2)(a). Per SDC 7:040 (2)(b), this citizen-initiated Type II
Metro Plan amendment can be initiated at any time.
5.0 Applicable Approval Criteria
Type II Metro Plan amendments are evaluated according to the criteria of approval
contained within SDC 7,070 (3), which provides:
"The following criteria shall be applied by the City Council in
approving or, denying a Metro Plan amendment application:
(a) The amendment must be consistent with the relevant
Statewide planning goals adopted by the-Land
Conservation and Development Commission; and
(b) Adoption of the amendment must not make the Metro
Plan internally inconsistent"
Findings demonstrating,consistency with the approval criteria are outlined below.
4-48
..
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 2007
Page 5
5.1 Consistency With Statewide Planning Goals
The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a).
Approval of a Metro Plan diagram amendment aha correspondingly changes the
applicable refinement plan diagram, as established in SDC 7,110 (4),
Goal I - Citizen Involvement
Goal I addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use planningprocess. The Plaffiling Commission
and the City Council will hold public hearings and accept testimony on the proposal.
Through the procedures established by the city, citizens will receive notice of hearings in
generally published local papers and have the opportunity tobe heard regarding the'
proposed diagram anlendment and zone change. Notice of the public hearings will also
, be given in accordance with SDC requirements to nearby property owners, interested
parties requesting notice, and any established neighborhood organization, Since the
amendments comply with the City's citizen involvement program and citizens have
opportunities to be involved in the procedure, the proposed amendments are consistent
with Goal L
Goal 2 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local
compreh~nsiveplans be internally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans, Goal 2 also requires that land use
decisions be coordinated with affected jurisdictions and that they be supported by an
adequate factual base. As required in SDC 7,050, the City is required to give referral
notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and
Lane County so they may determine if there are grounds to participate as parties to the
hearing, The City also sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of Land Conservation and Development;
ensuring that they are given opportunity for comment and review conformity to
applicable statewide planning goals,
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation of comprehensive plan
amendments. Compliance with these measures assures an adequate factual base for
approval ofthe proposed Metro Plan diagram amendment. As discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and the Goals,
Consequently, by demonstrating such compliance, the amendments satisfy the
consistency element of Goal 2, .
Goal 3 - Agricultural Lands
This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies only
to rural agricultural lands, The subject properties are located within an acknowledged
urban growth boundary, are inside Springfield's corporate limits, and have not been in
agricultural use for decades.
4-49
~
-
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15.2007
Page 6
Goal 4 - Forest Lands
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendments are inside Springfield's acknowledged UGB,
GoalS - Natural Resources
GoalS requires local governments to' protect a variety of open space, scenic, historic, and
natural resource values, Goal S and its impIementingrule, OAR Ch. 660, Division 16,
require planning jurisdictions, at acknowledgment and as a part of periodic review, to
(1) identify such resources;
(2) determine their quality, quantity, and location;
(3) identify conflicting uses;
(4) examine the economic, social, environmental, and energy
(ESEE) consequences that could result from allowing;
limiting, or prohibiting the conflicting uses; and
(S) develop programs to resolve the conflicts.
The subject properties are not on Springfield's acknowledged Metro Plan Goal S
inventory. No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site, The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
consulted and there are no jurisdictional wetlands located on the site. Therefore, the
proposed amendment does not alter the City's complian~e'with Goal 5,
Goal 6, Air, Water, and Land Resources Quality
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state, Generally, Goal 6 requires that development comply with
applicable state and federal air and water quality standards. In the context of the
proposed Metro Plan diagram amendment, Goal 6 requires that the applicant demonstrate
that it is reasonable to expect that applicable state and federal environmental ,quality
standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environmental clean-up list A Phase 1
environmental assessment on the subject property was conducted and recommended
additional analysis, Upon recommendations through the Phase 2 environmental
assessment a nominal quantity of soil (less than 10 cy) impacted by earlierlhistoric use
was removed from the site and properly disposed. Given the nominal impact generated
by historic uses on the site, it is reasonable to conclude that future development on the'
site will be able to demonstrate compliance with City standards for water quality
protection through the site plan review process, thereby complying with applicable state
and federal environmental quality standards.
4-50
Metro PlanlEMRP< Diagram Amendment
PeaceHealth Oregon Region
March 1 5.2007
Page 7
Goal7 - Areas Subject to Natural Hazards
Goal 7 requires that development subject to damage from natural hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation, The goal also
requires that plans be based on an inventory of known areas of natural disaster and
hazards, such as areas prone to landslides, flooding, etc. .
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area, Therefore, approval of the proposed Plan
amendments will not alter the City's acknowledged compliance with Goal 7 through its.
adopted plans, codes and procedures.
Goal 8 - Recreational Needs
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citi-zens of the state and
visitors," and where appropriate, provide for the siting of recreational facilitles including
destination resorts. The subject site is not included in an inventory of recreational sites,
and the proposed amendments will ,not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not,iinplicate Goal 8.
Goal 9 -'Economic Development
Goal 9 requires the city to provide adequate opportunities for a variety ofeconomic
activities vital to the health, welfare, and prosperity of the citizens, The proposed
'amendment to the Metro Plan diagram will increase the city's capacity for economic
development by adding 5 acres of CC in place of the existing industrial designation.
Permitting the construction of future clinic facilities and allowing long-standing
commercial uses on Tax Lot 402 to become conforming uses consistent with commercial
zoning is consistent with numerous policies in the City's adopted pl<in for compliance
with Goal 9, the Springfield Commercial Lands Study (SCLS).
Specifically, the following SCLS policies are applicable to the proposal:
Policy I-A: "Maintain a mixed supply oflarge and small commercial sites
through strategies such as rezoning or annexation to serve Springfield's
future population." '
The proposal fulfills this policy objective by redesignating and - through accompanying
zone change - rezoning land from industrial to commercial, for two tax lots of varying
sizes and commercial uses, thereby maintaining existing employment and commercia:l
use in Tax Lot 402 and providing the ability for growth in medical sector employment by
allowing future clinic uses on Tax Lot 400,
Policy I-C: "Maintain at least a five-year supply of commercial land
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable with a full range of urban public facilities and
services."
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The SCLS (see Table 3-8, pg, 32) found there to be a deficit of 158 acres in the supply of
commercial land over demand projected through the year 2015, The proposal would
allow for redesignation, and rezoning, of five acres thereby reducing the deficit of
commercial land. The subject site has a full range of urban public facilities and services
available to support existing commercial development on TaxLot 402, and future
development on Tax Lot 400. The SeLS identifies (pg. 33) a need to support
"employment in population-dependent sectors such as retail sales and health services" to
meet Springfield's growing community. The SCLSalso noted (pp, 27-29) state and local
trends in greater employment in retail trade and well-paying health services sectors.
Approving the proposed redesignation and zone change would help meet Springfield's
demonstrated need for employment and commercial services,
Finding 3 in the SCLS (pg. 36) cited'the acknowledged 1992 lridustrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area," Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit ide'ntified in the SCLS. Therefore, approving the proposal would be
consistent with SLCS ImplementationStrategy 3-A (I): "Evaluate inventories based on .
demonstrated need for the planning period, Initiate rezoning or redesignation of surplus
land uses where more appropriate for commercial, consistent with the Metro Plan."
The proposal in fact consistent with inventories for commercial and industrial lands
adopted by the City Council and acknowledged by DLCD as being consistent with .Goal'
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
0010(4)) call for amendments to land use desighations "in excess of two acres within an
existing urban growth boundary from an industrial land use designation to a non-
industrial use designation" to have to address applicable planning requirements - such as '
consistency with the Metro Plan and other local plan policies (i.e., SCLS) or be consistent
with an economic opportunities analysis, The City can find that the proposal complies
with relevant local plan policies by converting one fomi or employmenhgenerating land
use to another, without negatively impacting the supply of buildable lands for either
category of uses. The proposal enables continued use of the existing and long-standing
commercial center to continue to operate and provide employment opportunities, while
also allowing higher-value employment associated with future development on Tax Lot
400, These types of employment-generating uses are among those identified in OAR
660-009-0005(6) as eligible non-industrial employment activities that can justify
approval of the proposed Plan diagram amendment without the need for an economic
opportunities analysis apart from the SCLS, which DLCD acknowledged as fulfilling,the
City's obligations under Goal 9.
Because the requested redesignation and concu'rrent zone change implements SCLS
policies and does not result in a deficiency of needed industrial lands, and is otherwise
demonstrated to be consistent with relevant Metro Plan policies, approval of the request
is consistent with the City's compliance with Goal 9 and applicable administrative rules
regarding Goal 9 implementation.
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Goal 10 - Housing
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands, The proposal
does not affect the City's inventory ofresidentiallands,
In fact, approval of the requested redesigr>atidn for Tax,Lot 400 would enable
redevelopment of an industrial site abutting existing residential development. Through
the site plan review process, future development on that property will provide a superior
buffer and a higher use that will benefit the adjoining residential properties. Because the
proposal involves redesignation from industrial to commercial land uses, it does not
affect Springfield's continued compliance with Goal 10,
GoallI - Public Facilities and Services
This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services. The subject property is located within the Springfield UGB and
city limits, and is already desigr>ated for urban levels of use. The proposed amendment to
the Plan map desigr>ations from LMI to CC will not affect the ability to provide needed
services since all the required urban services are available to support existing or future
commercial uses on the subject site.
Goal 12 - Transportation
Goal 12 requires locai governments to provide and encourage a safe, convenient and
economical transportation system, The proposed map amendments involve
approximately 5,24 acres of property, though existing and long-standing commercial uses
occur on Tax LotA02 such that approval of the proposal will not result in any changes to
the type or intensity of uses on the site, and will not increase the trip 'generation for that
parcel. As the attached Traffic Impact Analysis' (TIA) demonstrates, future development
of medical office facilities on TL 400 will not degrade mobility standards below
acceptable levels and allow for adequate queuing lengths at applicable intersections.
Therefore, the proposal will not have a "significant effect" on transportation facilities as
defined in the Transportation Planning Rule (OAR 660-012-060).
Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to
retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some access. changes as will be reviewed
through the site plan review process, thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located approximately in the center of the
parcel. The TIA demonstrates that these access points will not result in any degradation
of mobility standards below acceptable levels, and that safe and efficient circulation can
be realized through approval of the requested land use redesigr>ation (and companion
zone change).
Furthermore, reducing the number of access points for future development on Tax Lot
400 is consistent with policy objectives found in East Main Refinement Plan (EMRP)
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"
Access, Circulation & Parking Element policy IB (pg. 17) and Cammercial Element
policy 3 (pg. 12).
Because the proposal, as demonstrated in the TIA, is cansistent with the requirements .of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and
applicable local implementing policies, '
Goal 13 - Energy Canservation
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amendments. The proposed amendment has no direct impact an energy
conservation, thaugh it would in fact will promote greater energy efficiency by enabling
needed clinical services available to grawing r,esidential areas in east Springfield.
, Therefore, the proposed amendment is consistent with, and does not alter the City's
continued compliance with Gaal13,
Goal 14 - Urbanization
Goal 14, requires local jurisdictions to pravide for an "orderly and efficient transition
from rural to urban land use," The subject property is within the UGB and the city limits
.of Springfield, and within an existing urbanized area .of the cammunity. Therefore, Gaal
14 is nat applicable to this application,
Goal 15 - WilIamette River Greenway
This goal is inapplicable because the subject property is not within the boundaries .of the
Willamette River Greenway.
Goals 16-19 - Coastal Goals
The coastal goals are not applicable to this application,
5.2 Metro Plan Consistency
The application requests amendment of the Metro Plan diagram from LMI ta CC far
approximately 5.24 acres. This section of the applicatian narrative addresses'the
consistency of the amendment with the applicable palicies of the Metro Plan, to
demonstrate that adoption of the amendment will not make the Metro Plan internally
inconsistent (as required by the approval criteria in SDC 7.070(3)(b)) ,
This narrative only addresses those palicies that apply to the proposal, and does not
discuss thase portians of the Metro Plan that: (I) apply only t.o rural or ather lands
.outside .of the urban growth baundary, (2) apply ta land uses ather than the current .or
proposed designatians for the site and will not be affected by the proposed Plan diagram
and text amendments, or (3) clearly apply only ta specific development applicatians (e,g.,
site plan review submittals .or subdivisians). In many instances the goals, policies and
implementation measures apply to specific develapment proposals that will be addressed
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through compliance with applicable City regulations during site plan review of a given
future development proposal.
The Metro Plan Introduction, Section D provides the following definitions:
A goal as a broad statement of philosophy that describes the
hopes of the people of the community for the fuhtre of the
community. A goal may never be completely attainable, but
is used as a point to strive for.
An objective is an attainable target that the community
attempts to reach in striving to meet a goal. An objective may
also be considered as ari intermediate point that will help
fulfill the overall goal. '
A policy is a statement adopted as part of the Plan to provide
a consistent course of action moving the community towards
attainment of its goals.
Except for the Growth Management Goals, which are addressed below, each of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan, . .
5.2.A,
Metro Plan Elements
1. Growth Management
Policies
1. The urban growth boundary and sequential development shall .
continue to be implemented as an essential means to achieve
compact urban growth. Provision of all urban services shall be
concentrated inside the urban growth boundary.
The proposed amendments satisfy this policy because the subject property is inside the
UGB and city limits and as such, encourages compact urban growth, Also, urban
services are available at sufficient levels to accommodate the existing and future infill
development resulting approval of from this application. The City's site plan review
processes ensure that the appropriate level of services is available to serve future
development. .
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2, Residential Land Use and HousingElement
Policies
A.l1 Generally locate higher density residential development near
employment or commercial services" in proximity. to major
transportation systems or within transportation-efficient nodes.
The proposed redesignation does not affect the inventory or availability ofresidentially
designated orzoned land, including the single-family residential area abutting Tax Lot
400 that is zoned and desigr1ated for Medium DensityResidential, or higher density
residential developments located east of the site along Main Street.
However, approval of the requested redesigr1ation to Community Commercial would
allow for residential areas proximate to the subject area to have close and efficient access
to existing commercial services on Tax Lot 402 'and to future medical facilities proposed
for Tax Lot 400, consistent with the above policy, The areas proposed for redesigr1ation
offer existing and future employment opportunities and provide commercial services
along a major transportation system that can support the needs of nearby residential
development.
A.22 Expand opportunities for a mix of uses in newly developing areas
and existing neighborhoods through local zoning and development
regulations.
The map amendment and concurrently proposed zone change will allow for existing
commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid-
and east"Springfield area, and for future clinical facilities to be developed to serve this
rapidly growing area of the community. Approving the requested redesigr1ation and zone
change would expand commercial opportunities to serve these neighborhoods consistent
with the above policy.
3, Economic Element
Policies
B.l Demonstrate a positive interest in existing and new industries,
especially those providing above-above wage and salary levels, and
increased variety of job opportunities, a rise in the standard of living,
and utilization of our existing comparative advantage in the level of
education and skill of the resident labor force, ,
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The proposed amendment is consistent with this policy because it will allow medical
clinic uses to.be developed to serve growing areas in east and south Springfield~ As is
observed in the Springfield Commercial Lands Study (pp. 27, 29), employment in health
services is growing and approving the requested redesignation will enable increased job
opportunities with higher than average wages thereby helping raise the standa~d of living
and meet the needs of Springfield citizens, consistent with the above policy,
B.2 Encourage economic development.which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force. '
The The construction of and the use of commercial and medical uses will utilize both
local and imported capital and will employ the local labor force in a variety of skill ed,
, semi-skilled, and unskilled positions, consistent with this policy.
B. 6 Increase the amount of undeveloped land zoned for light industry
and commercial uses correlating the effective supply in terms of
suitability and availability with the projections of demand.
The proposal will add approximately 5.24 acres of Community Commercial land,
consistent with recommendations to increase the commercial lands inventory made in the
Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan
Industrial Lands Study concluded that there is a deficit of needed commercial land, apd a
surplus of industrially zoned and designated land, Approval of the requested
redesignation will not cause the inventory of needed industrial, land to go into.a deficit,
but in fact would, consistent with the above policy. The proposal correlates the need and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopted SCLS. '
B,I1 Encourage economic activities which strengthen the metropolitan
area's position as a regional distribution, trade, health, and service
center,
The amendment will facilitate the development of medical uses that will serve the needs
of the growing residential areas in east, south and southeast Springfield, and strengthen
the metropolitan area's position as a premier locale for healthcare services, consistent
with this policy objective,
6, Environmental Design Element
policies
E. I In ~rder to promote the greatest possible degree of diversity, a broad
variety of commercial, residential, and recreational land uses shalf be
encouraged when consistent with other planning policies.
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Approval of the proposed map amendments will add just over 5 acres into the City's
inventory of commercially desigrlated and zoned land, thereby allowing for a variety of
needed commercial uses to occur on the subject property. Long-standing existing
commercial services on Tax Lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with
medical services that will serve the needs of the growing residential areas east and south
of the subject site, consistent with the above policy,
7. Transportation Element
Land Use Policies
F.3 Provide for transit-supportive hmd use patterns and developlrtent,
including higher intensity, transit-oriented development along major
transit corridors and near transit stations; medium-and high-density
residential development within one-quarter mile of transit stations,
major transit corridors, employment centers, and downtown areas; and
development and redevelopment in designated areas that are or could be
well served by e;-dsting or planned transit.
The proposed map amendment and concurrent zone change will enable land use patterns
and development consistent with the above policy, Approval of the proposal will allow
for higher intensity development along Main Street, a major transit corridor. An existing
LTD stop is located on the frontage of Tax Lot 400 (see photo, pg, 2, Appendix Aofthe
TIA), and will provide convenient access to existing and projected employment on the
subject site, as well as access for patients to future out-patient medical facilities projected
on Tax Lot 400,
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Transportation System Improvements: Roadways Policies
F.15 Motor vehicle level of service policy:
a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on the roadway system, These standards
shall be used for:
(1) Identifying capacity deficiencies on the roadway system,
(2) Evaluating the impacts on roadways of amendments to
, transportation plans, acknowledged comprehensive plans and
land-use regulations, pursuant to the TPR (OAR 660-012- ,
0060),
(3) Evaluating development applications for consistency with the
land-use regulations of the applicable local government
jurisdiction.
b. Acceptable and reliable performance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CATS) area, and
LOS D elsewhere,
c, Performance standards from the OHP shall be applied on state
facilities in the Eugene-Springfield metropolitan area,
In some cases, the level of service may be substandard. The local
government jurisdiction may find that transportation system .
improvements to bring performance up to standard within the planning
horizon may not be feasible, and safety will not be compromised, and
broader community goals would be better served by allowing a
substandard level of service. The limitation on the feasibility of a
transportation system improvement may arise from severe constraints,
including but not limited to environmental conditions, lack of public
agency financial resources, or land use constraint factors. It is not the
intent of TSI Raodway Policy #2: Motor Vehicle Level of Service to
require deferral of development in such cases, The intent is to defer
motor vehicle capacity increasing transportation' improvements until .
existilig constraints can be overcome or develop an alternative mix of
strategies (such as: land use measures, TDM, short-term safety
improvements) to address the problem,
Subsection a,(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR). The accompanyjng Traffic Impact Analysis
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provides the factual basis to determine that the proposed redesignation would not result in
a "significant-effect" as defined under the TPR (OAR 660-012-0060(1)),
Specifically, the proposal does ndt change the functional classification of Main Street or
any other nearby roadway, and it does not change the standards for implementing the
City's functional classification system ofroadways, as identified in the Regional
Transportation Plan, As demonstrated in the TI~, the proposal also does not: '
. Result in types or levels of traffic or access that are inconsistent with the functional
classification of Main Street or any other nearby roadway;
. Reduce performance of traffic on Main Street or other affected intersections to a level
that is below acceptable established performance standards; or
. Make performance of existing facilities worse (i.e" below acceptable mobility
standards) than would be the case other uses permitted under' existing designations. or
zomng.
Specific TPR findings are further located in the TIA, see pp. 31-32. Because the proposal
does not result in a "significant effect" as established by applicable OARs, no further
TPR analysis is required, The request is therefore consistent with the above policy,
8, Public Facilities and Service Element
G,] Extend the minimum level and full range of key urban facilities and
services in an orderly and efficient manner consistent with the growth
management policies in Chapter II-B, relevant policies in this chapter and other
Metro Plan policies.
The subject property is located in Springfield's city limits UGH. All necessary
infrastructure and key urban facilities/services are present to serve existing development
(Tax Lot 402) or are available to serve future infill development on Tax Lot 400, ,.
Therefore, the proposal is consistent with the above policy.
9. Parks and Recreation FacIlities Element Policies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment. '
10, Historic Preservation Element Policies
Policies in this element of the Metro Plan are not relevant to the requested diagrarri
amendment.
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11. Energy Element policies .
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment
8.0 East Main Refinement Plan Consistency
The following demonstrates how the proposal is consistent with applicable policies in the
East Main Refinement Plan (EMRP). .
1. Mixed-Use Element
Policy 2) Area #2
A) The following land uses are allowed under Community Commercial
zoning:
All Communitv Commercial uses subject to Article 18 of the
Springfield Development Code,
The proposal requests redesigr1ating the subject properties to Community Commercial,
and concurrently rezoning the properties to CC, as is allowed by the above policy and
consistent with other EMRP policies. Approval of the request would allow long-standing
existing commercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consistent with neighboring uses to the west and south, which are also zoned and
designated for commercial uses,
,2. Commercial Element
Criteria for Commercial Refinement Plan Desil!nation,
1. Generally, the Community Commercial refinement plan designation
shall be applied under the following circumstances:
A) where it is not an intrusion into wellcmaintained residential
neighborhoods;
The proposed redesigr1ation does not intrude into the existing residential area west
of the subject site along 44th Street, and is therefore consistent with the above
cri terion.
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B) where it does not increase conflict between Low Density
Residential and Commercial;
Although the abutting residential area is zoned Medium Density Residential, it is
developed in low density residential uses, Approval of the proposed
redesigr1ation ofthe subject sites would actually result in a decrease of conflicts
between abutting residential and non-residential land uses by allowing future infill
development on Tax Lot 400, and through the site plan review process
establishing improved landscaped buffers 'and a use more compatible than the
industrial uses that historically abutting this residential area.
C) where criteria for designating Medium Density Residential
land does not apply;
Criteria for designating MDR land does not apply to the subject site.
D) where legally created commercial uses exist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP.
E) where adequate customer and service access to an arterial
street can be provided; ,.. and
The subject site has adequate legal access bnto Main Street, which is classified as
an 'arterial street.
F) where designated Commercial on the Metro Plan Diagram, ,
Approval of this application would result in a Commercial designation on the
Metro Plan diagram, which would also automatically modify the desigr1ation on
, the EMRP diagram.
Policy 2) Apply site-specific Commercial refinement plan designations
to clearly define the limits of new commercial uses where there is not an
existing, legally established, and beneficial mix:ing of uses,
Approval ofthe requested redesignation wopld apply Commercial plan desigr1ations to
the subject properties, allowing the existing, legally established cotnmercial uses on Tax
Lot 402 to continue. It would also enable commercial uses to be established on Tax Lot
400, thereby defining the limits of new commercial uses between the pre-existing
commercial uses on Tax Lot 402 and others to.the west, and the developed industrial
business park to the east. Tax Lot 400 does not have an existing or beneficial mix of
uses, but has historically housed industrial yard-type operations, Therefore, approval of
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Metro Plan/EMRP Diagram Amendment
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the proposal would define the limits of new commerciaJ uses as called for in the above,
policy, and also provide the ability to make superior buffering and other improvements
associated with future development on Tax Lot 400 through the site plan review process.
Policy 3) Reduce the number of vehicular access points and require the
rebuilding of curbs and installation of sidewalks and street trees along
Main Street, through the Site Plan Review process and in public
improvement projects.
The proposal would result in reducing the number of existing access points as required
above. Through the Site Plan Review process, future development on Tax Lot 400 will
have a single driveway access onto Main Street, eliminating one of the two existing curb
cuts on this site. Sidewalks and street trees are already located along its Main Street
,frontage, consistent with the above policy.
Policy 4) P~ovide buffering between commercial and residential uses
, through Article 31 of the Springfield Development Code, Site Plan
Review process, , .
Existing residential uses along the east side of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400, Approval of the proposal would allow for
attractive infill development of future medical facilities that would provide (through the
SPR process) improved landscaped buffers between the future use and existing
residential area to the west - as required by Code, and consistent with the above policy.
~
3, Industrial Element
Policy 1)- The City shall encou'rage effortsofvarious agencies to attract
new and retain existing jobs and businesses.
Imvlementatiol1
, The City shall maintain a current inventory of vacant commercial and
industrial land and structures within the East Main area,
Consistent with the above policy, approval of the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal,
conforming land uses, and allow future development of new employment on Tax Lot 400
with higher than average wages and employment densities than the current desigrlation
and zoning allows.
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Metro Plan I Refinement Plan
Amendment Application
#LRP2007 -00013
Rezone Application
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Metro Plan Amendment from LMI to
Commercial and concurrent Zoning.
, Map Amendment from LMI to CC
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Questions?
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.
Propel 'lanning & Development
~ PeaceHealth'
March 28, 2007
DavidReesor, Planner II
City of Springfield
Development Services Department
225 Fifth Street
Springfield, OR 97477
Re: Plan Amendment (LRP2007-000\3), Zone Change (ZON2007-00012)
Mr. Reesor,
The following and attached is supplemental information for the above-referenced
applications for proposed Metro Plan diagram amendment and zone change in east
Springfield,
The proposal seeks to redesigflate and rezone approximately 5,24 acres on two parcels
from Light-Medium Industrial (LMI) to Commercial. As noted in the application
findings submitted last week, the Springfield Commercial Lands Study demonstrates that.
the City has a deficiency in needed commercially desigflated and zoned land, so
approving the proposal would help reduce the identified deficit in that land use category,
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local
jurisdictions and acknowledged by LCDC as being consistent with statewide planning
goals and the Metro Plan, specifically fulfilling the Eugene-Springfield area's obligations
under Goal 9 (Economic Development). The Metropolitan Industrial Lands Inventory
Report associated with the MILS identified "about 1,688 constraint-free industrial
acres.., .This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,172 acres." (pg, 73) The Inventory Report also stated: "The 1,688
constraint-free acres may be the best suited to meet short-term industrial demand,This
portion of the supply also exceeds the twenty year demand projection."
The City performed subsequent analysis of industrial land supply as part of periodic
review requirements to demonstrate compliance with statewide planning GoalS (Natural
Resources). As shown in Attachment A, that analysis indicated that even removing the
possible industrial acreage affected by Goal 5 protection measures (about 100 acres
debited from the Eugene and Springfield inventories) would leave a surplus of industrial
lands of between 1,600 and 2,122 acres metro-wide.
Staffs GoalS work also calculated the changes in industrial land supplies since 1991 as a
consequence of Metro Plan diagram changes (see Attachment B). This analysis
demonstrated a reduction in less than 90 acres of industrial hind over the past 15 years,
Phone' (541) 335-2593
Fax (541) 335-2595
RiverBend Annex 123 International Way Springfield, OR 97477
www,peacehealth,org/oregon 4-70
, Dedicated to E.rccptiljnal Medicine
and Compassionote Care
suggesting that there is still an ample supply of available industrial lands to meet existing
and future development needs, " .
This analysis -may also not reflect other changes within, industrially designated land
categories that would further off-set the proposed change to the site's LM! Plan
'designation and zoning, For example, 11.5 acres was added to the inventory of LM!
zoned and designated land due to City Council approval in April 1997 for land east of the
,28th/31" Street connector and north of Marc ala Road (Ordinance No. 5851). Insofar as
the City and metropolitan area continue to enjoy a surplus of needed Industrial land, and
specifically Heavy Industrial zoned and designated land, the above-referenced change
added more than enough acreage to the inventory of LMI.designated and zoned land to
off-set the proposal to remove only about 5 acres from the LMI inventory. '
We therefore.respectfully submit that the proposed Metro Plan diagram amendment and
zone change will not materially affect the inventory of needed Industrial land and will not
alter the City's continued compliance with Goal 9, '
With acceptance of the above findings and earlier findings arid narrative in the prior
submitted applications, we believe the applications are complete and ready to be set for
Planning Commission hearing. Please notify me when the hearing is set, and send me a
copy of the required hearing notice to DLCD for my files.
TJ.1anks for yoUr consideration of the above. If you need additional information, please ,
. contact me at your conveniellce.
.
Re~"./._h '~
plir~t,~Cp r~.
Director, Land Use Planning & Development
PeaceHeaIth Oregon Region
r
Attachments
4-71
A TT ACHMENT A
11,0 Impact of the Proposed Protections on Buildable U:md
Inventories '
This section estimates the impact ofthe recommended program for protecting
Springfield's resource areas on the inventory of buildable residential, commercial and
industrial land. The administrative rule quoted above is somewhat vague about how to
compute the impact. Some contend that the protected acreage should be subtracted from
the current inventory of buildable land. Others contend that the protected acreage should
be subtracted from the sumlus of buildable land that was determined at the adoption of
the inventory. Case law supports subtracting the protected acreage from the surpius of
buildable land.
Tables 11 ~ 1, 11-2, and 11-3 below summarize the amount of land that would be
subtracted from the Eugene-Springfield inventories 'of surplus of buildable residential,
commercial and industrial lands that were identified when each inventory was adopted.
Table 11-1. Analysis of Maximum' Possible Impact on Supply of Residential
Lands within the Eugene-Springfield Metropolitan Area
Residential Land Supoly
Eugene-Springfield Metropolitan Area Residential Lands
and Housing Study Surplus Acres
Low Demand Assumption
or
Hi,!!h Demand Assumotion
Acres Removed from Residential Designation by Previous
Plan Amendments.
Eugene
Springfield
Acres I
1862.00
or
790,00
Total'
-84.90
-52.03
-136.93
Maximum Possible Residential Acres Impacted by
Eugene Goal 5 Protection Measures
-445,77
Maximum Possible Residential Acres Impacted by
Springfield Goal 5 Protection Measures
Remaining Surplus
-14.18
1265,12
or
193,12 J
4-72
Table 11-2. Analysis of Maximum Possible Impact on Supply of .
Commercial Lands within the Springfield Urban Growth Boundary
I Commercial Land Supply'
I Springfield Commercial Lands Study (2000) projects a deficit of
commercial land. '
I Acres Removed from Commercia,l Designation by Previous Plan
Amendments* ' . , ' .
I Maximum Possible,Commercial Acres Impacted by Springfield's
Goal 5 Protection Measures '
I - - - Remaining Surlllus (Deficit)
Acres I '
'-158 acres I
-2.8 acres
-11.56 acres I
(-172.36 acres) !
Table 11-3. Analysis of Maximum Possible Impact on Supply of Industrial
Lands within the Eugene-Springfield Metropolitan Area
I Industrial L~nd Supolv
Metropolitanlndustrial Lands Inventory Report Surplus Acres
Low Demand Assumption
or.
High Demand Assumption
Acres Removed- from-Industrial Designation by Previous Plan
Amendments*
Eugene ,
Springfield
Acres I
2954.28
or
2432,28
Total
Maximum Possible Industrial Acres Impacted by Eugene Goal 5
Protection Measures
-642.30
-90.80
-732,80
-44,73
Maximum Possible Industrial Acres Impacted by Springfield
Goal 5 Protection Me'asures
Remaining Surplus
-54.43
2122.01
or
_ 1600.01 J
* Does not consider actions taken by Eugene to add additional lands to the surplus.
11.1 Impact on 'the Residential Lands Inventory
In 1999, the Eugene-Springfield Metropolitan Area Re.sidentiitl Land and Housing Study
(Residential Lands Study) estimated the amount of vacant buildable residehtialland in
the area. In Springfield, a total of3,087 acres of buildable lands wereidentified. The
Study classified wetlands listed on the Springfield Local Wetland Inventory as
unbulldable and were not included in the estimated supply of buildable residential lands,
Other'types of constraints were also considered and classified as unbuildable and were
not counted in the buildable residential land inventory, The list Of constraints included:
. Floodways;
4-73
.
,
.
.
.
.
Wetlands listed on the Springfield Local Wetlands Inventory larger than .25
acr~; .
Land within the easement of230 KV power lines;
Land within 75 feet of a Class A stream or pond;
Land within 50 feet of a Class B stream at pond; and
Small irregularly shaped lots,
since the Residential Lands Study did not include wetlands listed on the Local Wetlands
Inventory in the buildable lands inventory, it is assumed that protecting these wetland
sites from conflicting residential development will not reduce that inventory, The
development setbacks recommended for significant wetland sites in this study will
slightly reduce the'inventoried acreage of vacant' buildable land adjacent to wetland
features,
Wetland Setbacks
As noted in Table 11-4 below, about 9,95 acres oflow-density residential (LDR) and.59
acres of medium density residential (MDR) land will be removed from the residential
lands inventory by the 25-foot setback recommended for those ~etlands not already
protected by the 50 and 75 foot setbacks required by Springfield's stormwater quality
protection policies. Keep in mind that this is a worst case scenario and assumes that the
developer is unable to locate required stormwater facilities within the,recommended
'setbacks and that subdivision design calIDot arrange for the yard areas of affected
dwelling units to be placed adjacent to the wetland, thus reducing or eliminating lost
development area.
Riparian Setbacks
In addition to wetland setbacks, recommended riparian setbacks will also result in the
removal of vacant acreage from the inventory of buildable residential lands, As noted in
Table 11-4, about 3.42 acres oflow-density residential (LDR) and ,22 acres of medium .
density residential (MDR) land will be removed from the residential lands inventory by
the 25-foot setback recommended for those wetlands not already protected by the 50 and
75 foot setbacks required by Springfield's stormwater quality protection policies.
The combined impact of the proposed 25-foot setbacks for wetlands and riparian areas is
14.18 acres, This represents .45% of the 3,087acres of buildable residential land .
described in the 1999 Residential Lands Study.
In May 2004, a Residential Lands Study Monitoring Report was published, updating the
residential lands inventory to reflect development through 2003. The report estimated
that at the end of 2003 there was 1,361 acres ofremaining buildable residential land in
Springfield. The amount ofland removed from the buildable inventory by the 25-foot
wetland and riparian setbacks proposed by. this report represents about 1 % of remaining
1,361 acres,
4-74
. '
Table 11,-4. Vacant Residential Land within Proposed Protection Setbacks
Setback Distance
, Vacant
LDR
Acres
I Wetland Setbacks
I 25 foot
I 50 foot
I 75 foot
I
, I Riparian Setbacks
I 25 foot
I 50 foot
I 75 foot
I
I
Total
9,95
9.4
4.97
24.32
Total
Grand Total
3.42
6.06
4.97
14.45
38.77
Vacant
MDR
Acres
Total Acres
,59
2.73
4.15
7.47
,22
2.73
4.15
7.1
14.57
11.2 ImpaCt on the Commercial Lands Inventory'
I
J
10.541
12,13
I
9,121
31.79 J
I
3.641
8,79 I
9.12 j
21.55 I
53,341
The Springfield Commercial Lands Study (2000) listed several types of development
constraints that affecte~ commercial properties, These development constraints included:
Major transmission lines;
Hazardous waste sites;
Slopes greater than 15%;
Lots less than 6,000 square feet in size;
Lots with poor visibility;
Lots with inadequate access;
Hydric soils; ,
Unstable soils; .
Willamette Greenway and Greenway setbacks;
Floodway and floodway fringe;
Wellhead zone of influence;
Wetlands listed on the Springfield Local Wetland Inventory;
Other potentially regulated natural resource sites [Natural Resources Study
Inventory];
Sites with Plan/Zone conflicts.
The Commercial Lands Study classitied sites on the on the Springfield Local Wetland
Inventory as constrained. The presence of these wetlands was noted and the inventory of
vacant commercial lands was noted to reflect the c'onstraint. The riparian sites which are
part of this study were also included as constrained, since they were part of the draft
Springfield Inventory of Natural Resource Sites at the time Commercial Lands Study was
conducted. .
4-75
Since the Springfield Commercial Lands Study did not remove wetlands and riparian,
sites, protection measures proposed by this study willhave an impact on the inventoried
acreage of vacant commercial lands, The development setbacksrecommended for
significant wetland and riparian sites will further reduce the inventoried acreage of vacant
buildable commercial land adjacent to these resource sites. The extent of this impact is
discussed below. '
The Commercial Lands Study concluded that there was about 85 acres of vacant
buildable commercial land in Springfield. An additional 12 acres w'as projected for
redevelopment by the Study bringing the total to 97 buildable acres. Demand for vacant
comm-ercialland for the planning horizon 2015 was 255 acres, The 2000 Commercial
Lands Study concluded that there was a 158 acre deficit of buildable commercial land, '
Wetland Impacts
Table 11-5 shows that ,07 acres:ofvacant commercial 'land would be removed from the
Commercial Lands Inventory if wetland sites zoned for commercial development were
fully protected. The 25-foot wetland setback recommended by this study would remove
an additional 1.47 acres of vacant commercial land from development. This figure
assumes that the developer is unable to locate.required storInwater facilities or required
, landscaping within the recommended setbacks, thus reducing or eliminating lost
, development area.
The total impact on the Commercial Lands Inventory would be a reduction of 1,54 acres
if wetland sites and their setbacks were fully protected,
Riparian Site Impacts
Table 11-5 shows that about acres 2.78 of vacant commercial land lies within inventoried
riparian sites that are protected by the Springfield's Stormwater Quality Management
program. Therefore, no commercial acreage is removed from the Commercial Lands
Inventory by the implementation of proposed protections in this study. "As noted in
Table 11.-5, no vacant commercial land will be removed from the inventory by the
proposed 25-foot setbacks,
The total impact on the Commercial Lands Inventory would be a reduction of 1.54 acres
if wetland and riparian sites and their setbacks were fully protected. This represents 1.8%
of the 8'5 acres of buildable commercial land described in the Springfield Commercial
Lands Study.
Table 11-5. Vacant Commercial Land within Proposed Protection Setbacks
I Zoning District' Site '
Acreage
I Wetlands
I Community'- - - ,07
25 ft.
'Setback
50 ft,
Setback
75 ft.
Setback
Total
Acres
I
I
1
1.65 J
1.47
,11
o
4-76
\ Zoning District Site 25 ft. 50 ft. ' 75 ft. ' Total 1
Acreage Setback Setback Setback Acres
I Commercial 1
I Neighborhoof 0 0 0 0 01
Corrunercial
I General Office 0 0 0 0 01
\ Major Retail 0' 0 0 0 0
Corrunercial
I Wetland Total 0.07 1.47 I, 0.11 0 1.65
I Riparian Areas 5.381
.\ Commuruty 2,78 0 0 2.6
Commercial
I Neighborhood 0 0 0 0 0
Commercial . ,
I General Office 0 0 0 0 01
I Major Retail 0 0 .24 0 ,241
Commercial
I Riparian Total 2.78 0 0,24 2,6 . 1
5.62 I
I Grand Total 2.85 1.47 ,35 2.6 7.27 I
--
11,3 Impact on the Industrial Lands Inventory
The 1992 Metro Area Industrial Lands Study assessed the supply and demand for
industrial land in the greater Eugene-Springfield area, The study concluded that there
was about 709 acres of buildable industrial land within Springfield's UGH. Like ,the
Springfield Commercial Lands Study, the Industrial Lands Study noted those industrial
sites with wetland and riparian constraints but did not exclude them from the inventory.
For that reason, protection of wetland and riparian lands under the policies proposed by
this study will reduce the inventory of buildable industrial lands. The extent of this
impact is discussed below.
Wetland Impacts
GIS analysis shows that about 30.64 acres of vacant industrial land are affected by
wetlands that are not already protected by the Springfield Stormwater Quality
Management (SQM) program, These wetlands are recommended for protection by a 25-
foot development setback under the Springfield natural Resources Study. These setbacks
,add another 6.82 acres to the amount of industrial zoned land that would be removed'
from the Industrial Land Inventory if wetland sites and the setbacks were fully protected
under the policies recommended by this study. The total impact to the inventory of
industrial lands would be 37.46 acres, Table 11-6 shows the total acreage for land
affected by wetlands and the acreage protected by setbacks from both this program and
the existing SQM program, '
Riparian Impacts
4-77
GIS analysis shows that 13,70 acres of vacant industrial land are affected by riparian
areas are that not already protected by the Springfield Stormwater Quality Management
(SQM) program, These riparian areas are'recommended for protection by a 25-foot '
development.setback under the Springfield Natural Resources Study. These setbacks add
another 3.27 acres to the amount of industrial zoned land thai would,be removed from the
Industrial Land Inventory if wetland sites and the setbacks were fully protected under the
policies recommended by this study. The total impact to the inventory of industrial lands
would be 16.97 acres. Table 11-6 shows the total acreage for land affected by riparian
corridors and the acreage protected by setbacks from both this program and the existing
SQM prograni.,
Total Impact
ThetotaI impact on the Industrial Lauds Inventory would bea reduction of 54.43 acres if
all wetland and riparian sites protected by this program and their 25-ft setbacks were fully
. protected, This represents less than 1% ofthe 709 acres of buildable industrial land for
Springfield in the Industrial Lands Study,
Table 11-6. Vacant Industrial Land within P~oposed Protection Setbacks
Zoning Total Site 25 ft. 50 ft, 75 ft, Total
.. District Wetland Acres not Setback Setback Setback Acres
Site Protected
Acreage by SQM
I Wetlands
Light- 28.20 (n76) A,81 ,82 0 33,83
Medium
Industrial
I Heavy 13.16 (2,88) 2.01 19.15 0 34,32
Industrial.
I Campus .35 0 0 1.28 0 1.631
Industrial
Special 0 0 0 0 0 0
Heavy
Industrial
I Quarry 0 0 0 0 0 01
Mining
I Booth Kelly .13 0 0 .47 0 0,60
MU .
I Wetland 41.84 (30.64) 6.82 21.72 0 70.381
Total
Riparian Total Site 25 ft. 50 ft.. 75 ft. Total
Areas Riparian Acres not Setback Setback Setback Acres
Site Protected
Acrea!.!e by SQM
4-78
Zoning Total Site ' 25 ft. ' 50 ft. ' 75 ft. ' Total
DIstrict Wetland Acres not Setback Setback Setback Acres
Site Protected
Acreage by SQM
Light- 16.48 (10.89) 2,05 4,72 1.26 24.51
Medium
Industrial
I Heavy 68,31 (2,81) 1.22 ' 8.93 0 78.461
Industrial
. I Campus 3,22 0 0 2.83 .03 6.08
, Industrial .
Special 0 0 0 0 0 0
Heavy
Industrial
I Quarry .0 0 0 0 0 0
Mining .1.03\
I ~thKe!lY " .21 0 0 .82 '0
I Riparian 88.22 (13. 70) 3.27 17.3 1.29 110,08
,.Total I
I Grand Total 130,06 (44,34) 10.09 39,02 1.29 180.46 I
4-79
Metro Plan Diaqraffi Changes Affecting the SUP.Jly of Residential, Commercial and Industrial Land
~ I Changes-in Metro Plan Dei;i~ nations
ILDR MDR Icc NC ILMI IHI G&E 'NRAG
-0.1' 0,1
35.0 5.0
-5.3 0,0
0.0 0.0
0.0 0.0
-3.0 3.0
-0.9 0,9 .
....
I
co
C>
I
I
ILocal File Number
190-04-058
190-12-201
[92-04-77
193"01-33
93-01-12
193-06-087
194-10-0194
195-02-036
195-02-036
\95-02-036
95-02-036
195-02-036
95-08-0157
97-05-101
99-02-038
99-02-041
99-09-230
02-03-0062
02-03-0063
02-07-200
102-08-243
LRP-2002-12431,
ILRP-2004-00031
ILR ~~:d20,'"?t~:01?,t?1t,"~I""'" '....'''I' 99S,.)):ij"~',.! ..f '....7. 's'o' ikl'l'!'2, Mp'
r ;,~~! en I~ ;"oaS1l~mC~l;L ,,'lrG.'aii fj;t#:r ),'" ;1ii\l;L."'.,,:
6,5
5.3
0,5
3.7
LOR Low Density Residential
MDR Medium Density Residential
ce' Commercial Center
Ne Neighborhood Commercial
CI Campus Industrial .
LMI Light Medium Industrial
MU
-3.7
9.2
72.0
18.0
16.5
-34.5
-22,0
6.0
I
I
I
1
1
j
1
1
1
j
I
1.
1
1
0,41
33,0
". I ~
'""+'row"-"'-'~'-d''''C'W'',"--~'''",,,,,:~,, ~'7""','!<-a';k',"\f': ._-'MtJi"'~ft'5"" 'ji- "',
lTQtallJt'il'_tlJ~~JQr{R.i:!!:jJ~~ntla!~~ 1t'M8';'t~i;i1tJL "g,Q.
~', I
HI Heavy Industrial
POS Public Open Space
G&E Government and Education
NR Natural Resource
AG Agriculture
MU Mixed Use
):>
-l
-l
):>
()
:r:
S
m
Z
-l
m
11 PeaceHealth
March 15,2007.
Zone Change Application
Written Explanation of the Proposal
Applicant:
peaceHealth Oregon Region
770 E. II th Avenue
P.O. Box 1479
Eugene, Oregon 97440
Property Owners:
Hyland Business Park, LLC (Tax Lot 400)
1941- A Laura Street
Springfield, OR 97477
Attn: Shaun Hyland
(541) 726-8081
Andrew Head (Tax LotA02)
1616 Ardendale Ln.
Eugene, OR 97405
(541) 521-3403
Applicant's
Representative:
Philip Farrington, AICP
Director, Land Use Planning & Development
PeaceHealth Oregon Region
123 Intemational Way
Springfield, Oregon 97477
(54!) 686-3828 * Fax (541) 335-2595
pfarrington@peacehealth.org
1.0 Land Use Request
PeaceHealth Oregon Region (the "Applicant") requests approval to change the zoning
classification on the City's zoning map from Light Medium Industrial ("LM1") to , .
Community Commercial ("CC") for approximately 5.24 acres identified as Tax Lots 400
and 402 on Assessor's Map No. 17-02-32-00, This same acreage on the site is being
proposed for a concurrent amendment to the Metro Plan diagram (which automatically
also amends the East Main Refinement Plan diagram) from LM! toCC, as allowed in
Springfield Development Code ("SDC") 12.020 (1)(a)l,
4-81
Zone Change Application
PeaceHealth Bregon Region
March 15, 2007
Page 2
The area subject to the proposed rezoning is mapped on Attachment A, and is referred to
collectively in this application as the "subject properties:' or "site."
2.0 Project Purpose
The Applicant seeks to rezone (and through concurrent application, redesignate) the
subject properties to CC so they may be developed for commercial uses (i.e" Tax Lot
400), including a possible future medical clinic which could serve residents in the
growing east Springfield area, and to be allowed to continue long~standing commerciai
operations (i,e., Tax Lot 402). Approval of this land use request would preserve
employment and existing viable commercial operations on Tax Lot 402, and create stable
family-wage employment opportunities on Tax Lot 400 - a vacant and underused
industrial site, The proposal would also help beautify this portion of Main Street from its,
traditional industrial yard uses, and future development would provide a superior buffer
for residential uses to the west than currently exists.
As described in later sections of this narrative the proposal is consistent with East Main
Refinement Plan (EMRP) and the Metro Plan as required by approval criteria in SDC
12.030, 'In particular, this request - when considered with the concurrently submitted
Metro Plan diagram amendment (and automatic EMRP diagram amendment) - complies
with EMRP Policy 2: "Apply site-specific Commercial refinement plan designations to
clearly define the limits of new commercial uses where there is not an existing, legally
established, and' beneficial mixing of uses." (pg, 12) The proposal to allow for a broader, '
more beneficial range of commercial and employment-generating uses on the subject
properties, It would also improve the area and better distinguish and buffer adjacent
residential and industrial business park uses,
3.0 Site Context'
The subject properties include a currently vacant, flat parcel (Tax Lot 400) and existing'
commercial development (Tax Lot 402) east of 44th Street along Main Street in east
Springfield. The site is bordered on the south by Main Street, on the east by the Hyland
Business Park, on the north by an open area south of the Weyerhaeuser mill site (Tax Lot
400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises (e.g" a cabinet shop and karate school) fronting Main
Street and residential homes along 44'h Street west of Tax Lot 400. Commercial '
enterprises are located immediately south of the site across Main Street (e.g., Gray's
Garden Center).
J
While historically involved in agricultural uses, since around 1990 Tax Lot 400 was used
as a storage and sales yard for landscape organics and forest by-products, The current
property owners also used the site to store modular construction offices, tool trailers,'
construction equipment and concrete form plywood, Tax Lot 402 has had various
commercial services on site since the 1950s,
4-82
Zone Change Application
PeaceHealth Oregon Region
March \5, 200' .
Page 3
The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic
resources'. The site is within the Springfield Urban Growth Boundary, and both parcels
were annexed into ihe City of Springfield in 1960, The EMRP diagram (adopted in
1988) currently designates the subject property for industrial uses, . '
The abutting property to the east is designated LightlMedium Industrial in the EMRP
diagram and zoned LMI. The areas immediately to the west and south of the site fronting
Main Street are identified as being within Mixed-Use Area #2 in the EMRP, and are all
zoned Community Commercial. Property to the west of Tax Lot 400 aiong 44th Street is
. zoned and designated Medium Density Residential.
4,0 Applicable Approval Criteria
Zone change proposals are evaluated according to the criteria of approval contained
within SDC 12,030 (3), which requires: '
1. Consistency with applicable.Metro Plan policies and the Plan
, Diagran1;
2. ConsistencY with applicable Refinement Plans, Plan District maps,
Conceptual Development Plans and functional plans; and
3, That the property is provided with adequate public facilities, services
and transportation networks to support the use, or will be provided
concurrent with property development.
Legislative zone map amendments are also required to show that they meet the
criteria for Plan amendments outlined in SDC ArtiCle}; and that it complies with
the state Transportation Planning Rule (OAR 660-012-0060), where applicable, .
Findings demonstrating consistency with the approval criteria are outlined below,
.I
'4,1 Consistency with Metro Plan Text and Diagram
Consistent with SDC 12.030 (3)(aj, this narrative only addresses those policies that apply
to the proposal, and does not discuss those portions of the Metro Plan that: (I) apply only
to rural or other lands outside of the urban growth boundary, (2) apply to land uses other
than the current or proposed designations for the site and will not be affected by the
proposed Plan diagram and text amendments, or (3) clearly apply only to specific
development applications (e.g., site plan review submittals or subdivisions). In many
instances the goals, policies and'implementationmeasures apply to specific development
proposals that will be addressed through compliance with applicable City regulations
'during siteplan review of a given future development proposal. .
Except for'the Growth Management Goals, which are addressed below, each ofthe Metro
Plan policies are'addressed in the order in which they appear in the Plan Element section
of the Metro Plan.
4-B3
Zone Change Application
PeaceHealth 'Oregon Region
March 15, 20r7
Page4
4.1.1 Metro Plan Elements
1. Gro:wth Management
Policies
,
1. The urban growth boundary and sequential development shall
continue to be implemented as an essential me'ans to achieve
compact urban growth. Provision of all urban services shall be
concentrated inside the urban growth boundary.
The proposal satisfies this policy because the subject property is inside the UGB and city
limits and as such, encourages compact urban growth. Also, urban services are available
at sufficient levels to accommodate the existing and future infill development resulting
approval of from this application. The City's site plan review processes ensure that the
appropriate level of services is available to serve future development
2. Residential Land Use and Housing Element
Policies
A.l1 Generally locate higher density residential development near
employment or commercial services, in proximity to major
, tr~nsportation systems or within transportation-efficient nodes.
The prpposed redesigr>ation does not affect the inventory or availability of residentially
desigr>ated or zoned land, including the single-family residential area abutting Tax Lot
400 that is zoned and desigr>ated for Medium Density Residential, or higher density
residential developm~ntslocatedeast of the site alongMain Street.
However, appr~val oftlle requested redesigr>ation to Community Commercial would
allow for residential areas proximate to the subject area to have close and efficient access
to existing commercial services on Tax Lot 402 and to future medical facilities proposed
for Tax Lot 400, consistent with the above policy, The areas proposed for redesigr>ation
offer existing and future 'employment opportunities and provide commercial serVices
along a major transportation system that can support the needs of nearby residential
development.
A,22 Expand opportllllitiesfor a mi.."C of uses in newly developing areas
and existing neighborhoods through local zoning and development
regulations,
The proposed map amendment and zone change will allow for existing commercial uses
on Tax Lot 402 to continue to serve existing neighborhoods in the mid- and east-
Springfield area, and for future clinical facilities to be developed to serve this rapidly
growing area of the community. Approving the request would expand commercial
opportunities to serve these neighborhoods consistent with the above policy,
4-84
Zone Change ,Application
PeaceHealth Oregon Region
March 15,2007
Page 5
3. Economic Element
Policies
B.1 Demonstrate a positive interest in existing and new industries,
especially those providing above-above wage and salary-levels, and
increased variety of job opportunities, a rise in the standard of living,
and utilization of our existing comparative advantage in the level of
education and skill of the resident labor force,
, The proposal is consistent with this policy because it will allow medical clinic uses to be
developed to serve growing areas in east and south Springfield. As is observed in the
Springfield Commercial Lands Study (pp. 27, 29), employffientin health services is
growing and approving the requested redesignation arid zone change will enable
increased job opportunities with higher than average wages thereby raising the standard
of living and ineeting the needs of Springfield citizens, consistent with the above policy,
B,2 Encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force, .
The construction of and the use of commercial and medical uses will utilize both local
and imported capital and will employ the local labor force in a variety of skilled,
semi-skilled, and unskilled positions, consistent with this policy.
B.6 Increase the amount of undeveloped land Z()I1edfor light industry
and commercial uses correlating the effective supply in terms of
suitability (lnd availability with the projections of demand,
The proposal will add approximately 5.24 acres of Community Commercial land,
consistent with recommendations to increase the commercial lands inventory made.in the
Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan
Industrial Lands Study concluded thatthere is a' deficit 'of needed commercial land, and a
surplus of industrially zoned and designated land. Approval of the requested
redesignation and zone change will not cause the inyentory of needed industrial land to
go into a deficit, but in fact would be consistent with the above policy. Theproposal
correlates the need, suitability, and availability of the subject site for commercial uses
with the need for such uses as demonstrated in the adopted SCLS:
B.ll Encourage economic activities which strengthen the metropolitan
area's position as a regional distribution, trade, health, and service
center,
The amendment will facilitate the development of medical uses that will serve the needs
of the growing residential areas in east, south and southeast Springfield, and strengthen
the metropolitan area's position as.a premier locale for healthcare services, consistent
with this policy objective,
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Zone Change Application
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6, Environmental Design 'Element
Policies
E,l In 'order to promote the greatest possible degree of diversity, a broad
variety of commercial, residential, and r~creationallalld uses shall be
. encouraged when consistent with other planning polic(es.
Approval of the proposed map amendments will add just over 5 acres into the City's
inventory of commercially desigrtated and zoned land, thereby allowing for a variety of
needed commercial uses to occur on the subject property. Long-standing existing, '
, commercial services on Tax Lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with
medical services that will serve the needs of the growing residential areas east and south
of the subject site, consistent with the above policy.
7, Transportation Element
Land Use Policies
F,3 Provide for transit-supportive land use patterns and development,
including higher intensity, transit-oriented development along major
transit corridors mid near transit stations; medium- and high-density
residential development with ill one-quarter mile of transit stations,
major transit corridors, employment centers, and downtown areas; and
development and redevelopment in designated areas that are or could be
well served by e..r:isting or planned transit
The proposal will enable land,use patterns and development consistent with the above
policy, Approval of the requested zone chimge (and concurrent redesigrtation) will allow
for higher intensity development along Main Street, a major transit ~orridor. An existing
LTD stop is located on the frontage of Tax Lot 400 (see photo, pg, 2, Appendix Aofthe
TIA), and will provide convenient access to existing and projected employment on the
subject site, as well as access for patients to future out-patient medical facilities projected
on Tax Lot 400, . '
Transportation System Improvements: Roadways policies
F.15 Motor vehicle level of service policy:
a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on the roadway system. These standards
shall be used for:
(1) Identifying capacity deficiencies on the roadway system,
(2) Evaluating the impacts on roadways of amendments to
transportation plalls, acknowledged comprehensive plans and
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land-use regulations,pursuantto the TPR (OAR 660-012-
0060).
(3) Evaluating development applications for consistency with the
land-use regulations of the applicable local government
jurisdiction,
b. Acceptable and reliable performance is defined by the following
levels oj service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CA TS) area, and
LOS D elsewhere.
c. PerJormance standards Jrom the OHP shall be applied on state
facilities in the Eugene-Springfield met:opolitan area.
In some cases, the level oj service may be substandard, The local
government jurisdiction may find that transportation system
improvements to bring performance up to standard within the planning
horizon may not be Jeasible, and safety will not be compromised, and
broader community goals would be better served by allowing a
substandard level of service, The limitation on the Jeasibility oj a
transportation system improvement may arise from severe constraints,
including butllOt limited to environmental conditions, lack oj public
agency financial resources, or land use constraint factors. It is not the
intent oJTSI Raodway Policy #2: Motor Vehicle Level oj Service to
require deJerral oj development in such cases., The intent is to deJer
motor vehicle capacity increasing transport~tiiin' improvements until
e.x:isting constraints can be overcome or d~velop~tl alternative mL"C of
strategies (such as:, land use measures, TDl'rIf, short-term safety
'improvements) to address the problem.
Subsection a.(2) in the above policy requires an eval].lation ofthe proposal pursuant to .the
state Transportation Planning Rule (TPR). The accompariyingTraffic Impact Analysis
provides the factual basis to determine that the proposed fedesignation would not result in
a "significant effect" as defined under the TPR (OAR 660-012-0060(1)),
Specifically, the proposal does not change the functional classification of Main Street or
any other nearby roadway, nor does it change the standards for implementing the City's
functional classification system ofroadways, as identified in the Regional Transportation
Plan, As demonstrated in the TIA, the proposal also does not:
. Result in types or levels of traffic or access that are inconsistent with the functional
classification of Main Street or any other nearby roadway;
. Reduce performance of traffic on Main Street or other affected intersections to a level
that is below acceptable established rerformance standards; or
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nge Application
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, Page 8
,e performance of existing facilities worse (i.e., below acceptable mobility
~dards) than would be the case other uses permitted under existing designations or
mg.
mal TPR fmdings are further located in the TlA, see pp. 31-32. Because the '
J.l, does not result in a "significant effect" as established by applicable OARs, no
TPR analysis is required. The request is therefore consistent with the above
8. Public Facilities and Service Element
,s
G.1 Extend the minimum level and full range of key urban
facilities and services in an orderly and efficient manner consistent
with the growth management policies in Chapter II-B, relevant
policies in this chapter and other Metro Plan policies.
lbject property is located in Springfield's city limits DOB. All necessary
.ructure and key urban facilities/services are present to serve existing development
~ot 402) or are available to serve future infill development on Tax Lot 400.
fore, the proposal is consistent with the' above policy.
9. Parks and Recreation Facilities Element policies
es in this element of the Metro Plan are not relevant to the requested zone change.
. 10. Historic Preservation Element policies
es in this element of the Metro Plan are not relevant to the requested zone change,
the
11. Energy Element policies
:es in this element of the Metro Plan are not relevant to the requested zone change.
tin
)r
s
ioh
1
lvel
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4.2 Consistency with East Main Refinement Plan
The following demonstrates how the proposal is consistent with applicable policies in the
East Main Refinement Plan (EMRP).
j
1. Mb:ed-Use Element
Policy 2) Area #2
A) Thefollowing landuses are allowed under Community Commercial
zoning:
All Community Commercia! uses subject to Article18 of the
Springfield Development Code.
The proposal requests rezoning the subject properties from LMI to Community
Commercial (and concurrently redesignating the properties to CC),'as the above policy
and other EMRP policies allow, Approval of the request would allow long-standing
existing commercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consistent with neighboring uses to the west and south; which are also zoned and
desigrmted for commercial uses,
2. Commercial Element
Criteria for Commercial Refinement Plan Desi!!nation,
1. Generally, the Community COl/1me~cial r~jinement plan designation
shall be applied under the following circu!'lstances: '"
. ,- .
, A) where it is not an intrusion into well,maintained residential
neighborhoods; , .
The area proposed for rezoning does not intrude into the existing residential nrea
west of the subject site along 44th Street, and is therefore consistent with the
above criterion.
'..
B) where it does not increase conflict between Low Density
Residential and Commercial;
Although the abutting residential area is. zoned Medium Density Residential, it is
developed in low-density residential uses. Approval of the proposed rezoning of
the subject sites would actually result in a decrease of conflicts between abutting
residential and non-residential land uses by allowing future infill development on
.Tax -Lot 400, and through the site plan review process establishing improved
landscaped buffers and a use more compatible than the industrial uses that
historically abutting this residential area,
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C) where criteria for designating Medium Density Residential
land does not apply; ,
Criteriafor designating MDR land does not apply to the subject site,
'D) where legally created commercial uses exist;
,Tax Lot 402 has existing, long-standing cornffiercial uses that were_legally created
prior to development of the Metro Plan or EMRP. Tax Lot 400 has had a variety
of commercial services located on-site over the years,
E) where adequate customer and sen,ice access to an arterial
street can be provided; ." and'
The subject site has adequate legal access onto Main Street, which is classified,as
an arterial street.
F) where designated Commerfial on the Metro Plan Diagram.
Approval of the concurrently submitted Plan diagram amendment application
would result in a Commercial designation on the Metro Plan diagram, which'
would also automatically modify the designation on the EMRP diagram.
Policy 2) Apply site-specific Commercial refinement plan designations
to clearly definlf the limits of new commercial uses where there is not an
,existing, legally established, and beneficial mh:ing of uses.
Approval of the concurrently requested redesignation would apply Commercial plan
designations to the subject properties, allowing the existing, legally established
commercial uses on Tax Lot 402 to continue, It would also enable commercial uses to be
established on Tax Lot 400, thereby defining the limits of new commercial uses between
the pre-existing'commercial uses on Tax Lot 402 and others to the west, and the
developed industrial business park to the east. Tax Lot 400 does not have an existing or
beneficial mix of uses, but has historically housed industrial yard-type operations.
Therefore, approval of the proposal would define the limits of new commercial uses as
called for in the above policy, and also provide the ability to make superior buffering and
other improvements associated with future development on Tax Lot 400 through the site
plan review process, .
!
Policy 3) Reduce the nllmber ofvehicttlar access points and require the
rebuilding of curbs and installation of sidewalks and street trees along
Main Street, through the Site Plan Review process and in public
improvement projects,
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The proposal would result in reducing the number of existing access points as required
,above. Through the Site Plan Review process,future development on Tax Lot 400 will
have a single driveway access onto Main Street, eliminating one of the two existing curb
cuts on this site. Sidewalks and streeUrees are already located along its Main Street
frontage, consistent with the above policy..
Policy,4) Provide buffering between commetcial and residential uses
through Article 31 of the Springfield Development Code, Site Plan
Review process. '
Existing residential uses along the east side of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would allow for
attractive infill development offuture medical facilities that would provide (through the
SPR process) improved landscaped buffers between the future use and existing
residential area to the west - as required by Code, and consistent with the above policy.
3, Industrial Element
Policy 1) The City shall encourage efforts of various agencies to attract.
new and retain existing jobs and businesses,
Imolementation
The City shall maintain a current inventoryofvacantcommercial and
industrial land and structures within the East Main area,'
.- ..... .
Consistent with' the above policy, approval of the requested:zone change and
. redesignation will enable existing, long-standing jobs and businesses on Tax Lot 402 to
remain as legal, conforming land uses, and allow future development of new employment
on Tax Lot 400 with higher than average wages and employment densities than the
current designation and zoning allows.
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Zone Change Application
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4,3 Provision of Adequate Public Facilities
The subj~ct properties were annexed into the Springfield coi-porate limits in 1960, and
therefore are provided with City police, fire, and other government services. Other basic
infrastructure is in place to serve existing development on Tax Lot 402 and any future
development on Tax Lot 400. Specifically, sanitary sewer, stonnwater, and water lines
are all located along the site's Main Street frontage - all of which are adequate to serve
the needs of existing 'and/or future development on the subject site. Transportation
services are also readily available to serve existing and future development, as Main
Street is fully improved with curb, gutter, etc.
As indicated in the Traffic Impact Analysis accompanying the concurrently submitted
zone change and Metro Plan diagram amendment, approval ofthe proposal would not
result in a "significant effect" to the transportation system, and therefore is consistent
with the state Transportation Planning Rule. The TIA further demonstrates that existing
and future developI(lent under the proposed zone change has safe and efficient access and
circulation for vehicles, and also will benefit from the sidewalks, bike lanes, and transit
service existing on Main S tree!.
Therefore, the proposed zone change complies with the requirement for having adequate
public,facilities and services to serve development, as established in SDC 12.030 (3),
4,4 Consistency with Approval Criteria in SDC Article 7
The proposed zone change is submitted concurrently with an application to amend the
Metro Plan diagram, The following findings are contained in the Plan diagram
amendment application, and also demonstrate that this proposal complies with Metro
Plan policies as required inSDC 7.070 (3) and with zone change approval criteria in SDC
12,030. Both the findings below relative to Goal 12 and those above' pursuant to Metro
Plan Transportation Element policies address consistency with the state TPR, as called
for in SDC 12.030.
It should also'be noted that approval of a Metro Plan diagram amendment also
correspondingly changes the applicable refinement plan (East Main Refinement Plan)
diagram, as established inSDC 7.\10 (4),
Goall - Citizen Involvement
Goal I addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use planning process. The Planning Commission
and the City Council will hold public hearings and accept testimony on the proposal.
Through the procedures established by the city, citizens will receive notice of hearings in
generally published local papers and have the opportunity to be heard regarding_the
proposed diagram amendment and zone change. Notice of the public hearings will also
be given in accordance with SDC requirements to nearby property owners, interested
parties requesting notice, and any established neighborhood organization. Since the
.process complies with the City's citizen involvement program and citizens have
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Zone Change..Application
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opportunities to be involved in the procedure, the proposed plan and zone map
amendments are consistent with Goal I , '
Goal 2 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local'
comprehensive plans be internally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans. Goal 2 also requires that land use
decisions be coordinated with affected jurisdictions and that they be supported by an
adequate factual base. As required in SDC 7,050, the City is required to give referral
. notice of the proposed Type, II Metro Plan diagram amendment to the City of Eugene and
Lane County so they may determine if there are grounds to participate as parties to the
hearing. The City also sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of Land Conservation and Development,
ensuring that they are given opportunity for comment and review conformity to
applicable statewide planning goals, '
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for.the evaluation of comprehensive plan
amendment and zone change proposals. Compliance with these measures assures an
adequate factual base for approval of the proposals'. As discussed elsewhere in this
. document, the Plan diagram and zone map amendments are consistent with the Metro
Plan and the Goals, Consequently, by demonstrating such compliance, the proposal
satisfies the consistency element of Goal 2, ' " ,.' ,'.
Goal 3 - Agricultural Lands
This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies only
to rural agricuiturallands, The subject properties are located within an acknowledged
urban growth boundary, are inside Springfield's corporate limits, and have not been in
agricultural use for decades.
Goal 4 - Forest Lands
Goal 4 does not apply \vithin urban growth boundaries, per OAR 660-06-0020, and the'
a;eas affected by the Plan amendments are inside Springfield's acknowledged UGB.
GoalS - Natural Resources
Goal 5 requires local governments to protect a variety of open space, scenic, histonc, and
natural resource values. Goal 5 and its implementing rule, OARCh. 660, Division 16',
require planning jurisdictions, at acknowledgment and as a part of periodic review, to,
(1) identify such resources;
(2) determin~their quality, quantity, and location;
(3) identify conflicting uses;
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(4) examine the economic, social, environmental, and energy
(ESEE) consequences that "could result from allowing,
limiting, 'or prohibiting the conflicting uses; and
(5) develop programs to resolve the conflicts.
The subject properties are not on Springfield's acknowledged Metro Plan Goal 5
inventory. No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site. The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
. consulted and there are no jurisdictional wetlands located on the site..Therefore, the
proposal does not alter the City's compliance with Goal 5.
Goal 6 -Air, Water, and Land Resources Quality
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires that development comply with
applicable state and federal air and water quality standards. In the context of the
proposed Metro Plan diagram amendment an~ zone change, Goal 6 requires that the
appiicant demonstrate that it is reasonable to expect that applicable state and federal
environmental quality standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environrrient~l clean-up list. A Phase I
environmental assessment on the subject property was conducted and recommended
additional analysis. Upon recommendations through the Phase 2 environmental
assessment a nominal quantity of soil (less than 10 cy) impacted by earlierlhistoric use
was removed from the site and properly,disposed. Given the nominal impact generated
by historic uses on the site, it is teasonabie to conclude that future development on the
site will be able to demonstrate compliance with City standards for water quality
protection through the site plan"review process, thereby complying v.:ith applicable state
and federal environmental quality standards.
Goal7 - Areas Subject to Natural Hazards
Goal 7 requires that development subject to damage from natural hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation. The goal also
requires that plans be based on an inventory of known areas of natural disaster and
hazards, such as a;eas prone to landslides, flooding, etc.
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area. Therefore, approval of the proposal will not alter
the City's acknowledged compliance with Goal 7 thrO\lgh its adopted plans, codes and
procedures.
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Goal 8 - Recreational Needs
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citizens of the state and
visitors," and where appropriate, provide for the siting of recreational facilities including
destination resorts. The subject site i"s not included in an inventory of recreational sites,
and the proposal will not have an impact on the community's recreational facilities or
needs; therefore, the proposal does not implicate Goal 8.
Goal 9 - Economic Development
. Goal 9 requires the city to provide adequate opportunities for a variety of economic
activities vital to the health, welfare, and prosperi!)' of the citizens. "The proposed
amendment to the Metro Plan diagram will increase th.e city's capacity for economic
development by adding S acres of CC designated/zoned land in place of the existing
industrial designation and zoning. Permitting the construction of future clinic facilities
on Tax Lot 400 and allowing long-standing commercial uses on TaX Lot 402 to continue
and become conforming uses consistent with commercial zoning through approval ofthe
proposed Plan diagram amendment and zone change is consistent with numerous policies
in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands
Study (SCLS). . "
Specifically, the following SCLS policies are applicable to the proposal:
Policy I-A: "Maintain a mixed supply oflarge and small'commercial sites
through strategies such as rezoning or annexation to serve Springfield's
future population."
The proposal fulfills this policy objective by rezoning (and redesignating) land from "
industrial to commercial use, for two tax lots of varying sizes and coniinercialuses;
thereby maintaining existing employment and commercial use in Tax Lot 402 and'
providing the ability for growth in medical sector employment by allowing future clinic
uses on Tax Lot 400.
Policy.I-C: "Maintain at least a five-year supply of commerciallaod"
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable with a full range of urban public facilities and
services."
The SCLS (see Table3-S, pg. 32) found there to be a deficit of IS'S acres in the supply of
commercial land over demand projected through the year 201S. The proposal would "
allow for redesignation and rezoning of five acres thereby reducing the deficit of
cornmercialland. The subject site has a full range of urban public facilities and services
available to support existing commercial development on Tax Lot 402, and future"
development on Tax Lot 400. The SCLS identifies (pg. 33) a need to support
"employment in population-dependent sectors such as retail sales and health services" to
meet Springfield's growing community" The SCLS also noted (pp. 27-29) state and local
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Zone Change Application
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J
trends in greater employment in retail trade and well-paying health services sectors.
Approving the proposed redesignation and zone change would help meet Springfield's
demonstrated need for employment and commercial services.
Finding 3 i'n the SCLS (pg: 36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area." Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit identified in the SCLS. Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy 3-A (I): "Evaluate inventories based on
demonstrated need for the planning period. Initiate rezoning or redesignation of surplus
land uses where more appropriate for commercial, 'consistent with the Metro Plan."
The proposal in fact consistent with inventories for commercial and industrial lands
adopted by the City Council and acknowledged by DLCD as being consistent with Goal
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
0010(4)) call for amendments to land use designations "in excess of two acres within an
existing urban growth boundary from an industrial land use designation to a non,
industrial use designation" to have to address applicable planning requirements - such as
consistency with the Metro Plan and other local plan policies (i.e., SCLS) or be consistent
with an economic opportunities analysis. The City can find that the proposal complies
with relevant local plan policies by converting one form or employment-generating land
use to another, without negatively impacting the supply of buildable lands for either
category of uses. The proposal enables continued use of the existing and long-standing
commercial center to "continue to operate and provide employment opportunities, while.
also allowing higher-value employment associated with future development on Tax Lot
400.' These types of employment-generating uses are among those identified in OAR
660-009-0005(6) as eligible non-induSllial employment activities that can justify
approval of the proposed Plan diagram amendment without the need for an economic.
opportunities analysis apart from the SCLS, which DLCD acknowledged as fulfilling the'
City's obligations under Goal 9.
. Because the requested redesignation and zone change implements SCLS policies and
does not resuit in a deficiency of needed industrial' lands, and is otherwise demonstrated'
to be consistent with relevant Metro Plan policies," approval of the proposal is consistent
with the City's compliance with Goal 9 and applicable administrative rules regarding
Goal 9 implementation.
Goal 10 - Housing
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands. The proposal
does not affect the City's inventory of residential lands"
In fact, approval of the requested redesignation for Tax Lot 400 would enable
redevelopment of an industrial site abutting existing residential development. Through
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Zone Chang~ Applicatinn
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the site plan review process, futur~ development o~ that property can provide a superior
buffer and a higher use that will benefit the adjoining residential properties. Because the.
proposal does not involve directly any change in the amount of residentially designated
or zoned land, it does not affect Springfield's continued compliance with Goal 10.
Goalll - Public Facilities and Services
This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services. The subject property is located within the Springfield UGB and
city limits, and is already designated for urban levels of use. The proposed amendment to
the Plan map designations and zone map classifications from LMI to CC' will not affect
the ability to provide needed services since all the required urban services are available to
support existing or future commercial. uses on the su~ject site.
Goal 12 ~ Transportation ",
Goal 12 requires local go"vemrnents to provide and encourage a safe, convenient and
economical transportation system. The proposed map "amendments and zone change
involve approximately 5.24 acres of property, tl,1ough existing and long-standing
commercial uses occur on Tax Lot 402 such that approval of the proposal will not result
in any changes to the type or intensity of uses on the site, and will not incn:ase the trip
generation for that fully developed parcel. As the attached Traffic Impact Analysis (TIA) .
demonstrates, future development of medical office facilities on TL 400 will not degrade
mobility standards below acceptable levels and allow for adequate queuing lengthsa:t
applicable intersections. Therefore, the proposal will not have a "sigillficant effect" on
transportation facilities as defined in the Transportation Planning"Rule (OAR 660-012-
060). . ~'.
Existing'development at Tax Lot 402 is not affected by the proposal, and is assumed to
retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some access changes as ,vill be reviewed
through the site plan review process, thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located approximately in "the center of the
parcel. The TIA demonstrates that these access points will not result in' ariy degradation
of mobility standards below acceptable levels, and that safe and efficient.circulation can
be realized through approval of the requested land use redesignation and zone change,
Furthermore, reducing the number of access points for future development on Tax Lot
400 is consistent with policyobjectives found in East Main Refinement Plan (EMRP)
Access, Circulation & Parking Element policy I B (pg. 17) and Commercial Element
policy 3 (pg. 12).
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and
applicable local implerr;enting policies.
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Goall3 - Energy Conservation
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amendments. The proposal has no direct impact on energy
conservation, though it would in fact will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore, the proposal is consistent with, and does not alter the City's continued
compliance with Goal 13.
Goal 14 - Urbanization
Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition
from rural to urban land use." The subject property is within the UGB and the city limits
of Springfield, and within an existing urbanized area ofthe community. Therefore,"Goal
14 is not applicable to this application.
Goal 15 - Willamette River Greenway
This goal is inapplicable because the subject property is not within the boundaries of the
Willamette River Greenway.
Goals 16-19 - Coastal Goals
The coastal goals are not applicable to this application.
4-98
Staff Response to written comments to Applications
ZON 2007-0ooi2 / LRP2007-00013
EXECUTIVE SUMMARY:
Staff received one written testimony from Lauri Segel, Goal One Coalition Planner, on
June 12th, 2007. A written rebuttal to Ms. Segel's letter was then submitted by the
applicant the following day, June 13th, 2007. Both letters were ~eceived within the
specified deadlines as noted in the Planning Commission public hearing on June Sth,
2007. Excerpts from Ms. Segel's letter and the applicant's rebuttal letter have been
provided in this report (in italics) in order to summarize the issues and to provide ease of
review by the Planning Commission. Copies of the ty.>o letters in their entirety are
attached for reference and review in addition to the excerpts and Staff responses in this
report.
Ms. Segel's Submittal - Issue #l: '.'Applicant Relies heavily on the acknowledged
2000 Springfield Commercial Lands Study (SCLS), which does not address the
entire Metro UGB area, and is not a refinement plan of the Metro Plan... The
proposed findings rely on reports and other documents containing inventories,
assumptions, and data that have not been established for the entire Metro UGB
area, but rather only for the Springfield portion of the UGB area.....
Aoolicant's Rebuttal: "The cities of Eugene and Springfield have separately.
adopted and acknowledged commercial lands studies fulfilling the requirements
,of Goal 9. As such, the SCLS serves as the City of Springfield's "most recent
economic opportunities analysis, " as Ms. Segal notes above by her own
admission... There is no requirement that theApplicant or the City perform a
metro-wide analysis of commercial lands in order to adopt findings satisfying
compliance with Metro Plan policies and Goal 9... ..
. STAFF RESPONSE: The SCLS was a Period Review Task required by DLCD and' was
approved by said agency as part of Springfield's compliance with Goal 9 during the
Periodic Review process. As such, it is a valid document to reference related to this Post
. Acknowledgement Plan Amendment (PAPA) proposal. The SCLS was adopted by
Resolution No. 00-13 as the "policy document guiding the provision of commercial lands
within the Springfield Urban Growth Boundary." The SCLS was reviewed by DLCD and
found to be consistent with the Periodic Review Order and Statewide Planning Goals.
The SCLS was not adopted as a specific amendment to the Metro Plan. The City
undertook a supply and demand analysis todetermi)le if there was adequate commercial
land in the adopted inventory to accommodate projected demand and, based on these
conclusions, identify what the City could do to address these conclusions. Chapter 4 of .
the SCLS, which includes policies and implementation strategies, all recommended .
actions are already in the Metro Plan or TransPlan; are a recommendation to amend the
Code; or are suggestions to improve business practices. The City and DLCD concluded
4-99
. .
it was not necessary to adopt the SCLS as an amendment to the Metro Plan because all
recommendations regarding inventory adjustments contained in the Study could be
implemented through the PAPA process as increases in the commercial lands inventory;
the.SCLS wQuld be used at that time as part of the findings, reasons and conclusions for
those PAPA actions. .
Best available data was used in the analysis of these applications, which included the
SCLS. There are no comprehensive studies (i.e. commercial lands inventory) available
for the entire UGB related to commercial lands within one specific time period. Rather,
there is a conglomeration of various studies that are reviewed. For example, the 1992
Industrial Lands study is UGB-wide. The Residential Lands Inventory which is used by
the City is not UGB-wide. Likewise, the SCLS is not Metro-wide.
Ms. Segel's Submittal - Issue #2:. "The adopted Springfield Natural Resource
Study (adopted by Ordinance #6150) shows little or no impact on the commercial
lands inventory from Goal protection measures, and provide little if any analyses
of land availability within the entire Metro UGS area, ratherthanjust the
Springfield UGS area. The analysis shows an impact of 11.56 acres on
Springfield's (not the urban growth boundary area in its entirety)... The
referenced studies / analyses referenced by the applicant do not take into account
the 100 acres of new commercial land designated / rezoned to commercial in the
Gateway area. "
Aoolicant's Rebuttal: "Considering that the SCLS identified a deficit of 158
acres in the supply of commercial land over demand, accountingfor this
additional redesignated/rezoned land, this would still result in a deficit of more
than 61 acres of needed commercial land. Approving the requested Plan
amendment/zone change would still leave a deficit of approximately 55 acres of
needed commercial land... Therefore, even considering impacts to commercial
lands inventories from other adopted and acknowledged plans (i.e. the City's plan
. for Goal 5 compliance) and acknowledged Plan amendments / zone changes,
approval of the proposal will not result in .there being an excess of needed
commercially zoned and designated land. To the contrary, this analysis
demonstrates that there will remain a deficit of approximately 66 acres after
approval of the requested redesignation / rezoning. " .
STAFF RESPONSE: The Springfield Natural Resource Study (SNRS) is referenced by
the applicant and staff as related to this PAPA because it provides a more updated view
of the city's commercial & industrial lands inventory. It is riot meant to be all inclusive in
. "
and of itself. Reference to the SNRS in conjunction with other referenced documents (i.e.
the SCLS" & 1992 Industrial Lands Study) is provided to give the most accurate
information possible given all the available data at this time.
Again, the applicant's report and staffs analysis reference the most recently adopted
documents / inventories available. The City currently does not have an ongoing database
"--1I1n
that keeps track of inventories based upon Plan Amendments and/or Zoning Map
Amendments on an ongoing basis. .
The applicant's rebuttal references numbers of acres related to the City's deficit of
cornmercialland. Staff concurs with the applicant's rebuttal related to number or'acres of
cornmerciallands. The redesignation and rezoning of up to 99 acres ofresidentialland
within the Gateway MDR site (as referenced by Ms. Segel) still does not negate the
deficit of commercial land within Springfield's city limits. .
Ms. Segel's Submittal- Issue #3:" "The applicant has not justified the
conversion of scarce, shovel ready industrial land, especially land designated and
zoned light medium industrial inside"the Metro UGB, even though the Metro Plan
(comprehensive plan) Econon;ic Element policy #12 establishes that the cities are
"to 'discourage filture Metropolitan Area General Plan amendments that would
change development ready industrial lands (sites defined as short-term in the
metropolitan Industrial Lands Special Study, 1991) to noh-industrial
designations.' The applicant and stafffindings do not address how the loss of
these 5.24 acres impacts the short-term supply of LM] designated land... "
Aoolicant's Rebuttal:. "Ms. Segel's citation of Economic Element Policy 12 .
ignores the fact that the subject site was not included among the sites "defined as
short-term in the metropolitan Industrial Lands Special Study, 1991). "...casting
doubt on the applicability of Metro Plan Economic Element Policy 12... Even if
Policy 12 were relevant, it's language is clearly not prohibitive to approval of an
application for redesignation/rezoning of an industrial site, particularly when
considering it in the context of industrial commercial land inventories. ...even if
all of the acreage redesignated in Springfield were from the LM] designation -
which is no doubt not the case - there would stili be a surplus of nearly 50 acres
of LM] designated land even after approval of the requested Plan amendment.
This does not accountfor the 11.5 acres"ofland added to the inventory of LM]
zoned and designated land referenced in' my March 28, 2001 supplemental
information. ... Therefore, the removal of 5.24 acres of LM] zoned and designated
land will not result in a deficit of needed land in that industrial designation.
...Moreover, although Economic Element Policy 12 "discourages" Plan
amendments for certain industrial lands, there are countervailing policies in the
Metro Plan (i.e., Economic Element Policy 6) and SCLS (i.e.. Policies 1-A and 1-
C) that are directive to providing an adequate supply of needed commercial
lands... "
ST AFF RESPONSE: Staff concurs with the applicant's rebuttal to the issue raised. The
applicant has cited numerous acreage calculations based off of adopted inventories which
support the proposal. As noted by the applicant, the subject site was not included among
the sites defined as short-term in the metropolitan Industrial Lands Special Study, 1991.
As noted in the applicant's rebuttal and as previously noted in this report and the original
Staff Report, a deficit of commercial land and surplus of industrial land will still exist
4-101
even after an approval of the proposed Plan Amendment and concurrent Zoning Map
Amendment. .
Ms. Se<,el's Subinittal- Issue #4:. "The Applicant 's analysis of the proposals ,
consistency with comprehensive plan Economic Element policies found in the
Metropoliti:m General Plan, Chapter III,B-I - B-7 is insufficient and does not
address the most significant policies that must be considered. "
. Aoolicant's Rebuttal:. "...there are countervailing policies in the Metro Plan
(i.e., Economic Element Policy 6) and SCLS (i.e., Policies I-A and I-C) that are
" directive to providing an adequate supply of needed commercial lands. The Metro
Plan recognizes such conflicts: "The respective jurisdictions recognize that there
are apparent conflicts and inconsistencies between and among some goals,
objectives, and policies. When making decisions based on the Plan, not all the
goals, objectives, and policies can be met to the same degree in every instance.
Use of the Plan requires a 'balancing' of its various components on a case-by-
case basis, as well as a selection of those goals, objectives, and policies most
pertinent to the issue at hand." (pg 1-4, Metro Plan)...The applicant's original
March 15, 2007 submittal included findings addressing relevant Metro flan
policies (see pg. 5 of the submittal: pg. 4-5 of the Commission's June 4, 2007
hearing packet). Clearly not all of the 32 Metro Plan Economic Element policies
are relevant to the proposal. Many are aspirational in nature and not directive to
a specific quasi-judicial application...
. ST AFF RESPONSE: As noted in the applicant's rebuttal, policies in the Metro Plan are
sometimes conflicting"to one another. As stated on page'I-4 of the Metro Plan, "The
respective jurisdictions recognize that there are apparent conflicts and inconsistencies .
between and among some goals, objectives, and policies. When making decisions based
on the Plan, not all the goals, objectives, and policies can be met to the same degree in
every instance. Use of the Plan requires a 'balancing' ofits.varloUS components on a
case-by-case basis, as well as a selection of those goals, objectives, and policies most
pertinent to the issue at hand." The applicant submitted written statements relative to the
policies which supported the prop~sal. As noted in the original Staff Report, St~ff
concurred with the applicant's narrative related to the referenced Metro Plan policies
which support the proposal, given the relationship of those stated Metro Plan.policies as
reviewed concurrentlv with the referenced cornmercial and industrial adopted inventories.
Ms. Se<,el's Submittal- Issue #5:. "The applicant is not specific about what uses'
will be cited should the proposal be approved, and there is no way to know if in
fact above wage jobs and salaries... there is no way to establish if the applicant
will infact utilize local and imported capital, skills etc. as no commitment to a use
has been established... "
ADolicant's Rebuttal: "...Ms. Segel's assertion that the application was
unspecific as tothefiilllre uses on Tax Lot 400 is inaccurate. The application
narrative clear(v states the intended purpose of the redesignation/rezoning is to
" /
4-1Q?
allow for aflllure medical clinic on Tax Lot 400 and to allow the long-standing
commercial operations qn Tax Lot 402 to continue (pg. 2, pg 4-2 in the
Commission's June 4 hearing packet). Such clinical uses are not permitted in any
industrial zoning district, thus promopting the need to rezone (and Redesignate)
Tax lot 400 to allow a medical clinic. Average wages and benefits for medical
workers tends to be higher than average local wages, and fllrther substantiating
data can be entered into the record at the City Council level...
STAFF RESPONSE: The applicant has noted the intent of the Plan,Arnendment and
concurrent zone change is for the eventual development of a medical office building. This
is mentioned not only in the applicant's narrative, but also in the applicant's Traffic
Impact Analysis. In fact, the referenced table in the TIA (Table 7, pg. 19) specifically
calculates trip generation for !he nro1)osed medical office building.l'!owever, as noted by
Ms. Segel, there is no certainty as to 'what the salaries will be, if it will utilize local
capital, etc. With that said, there is no such assurance for any new use,that might go on
the property with the existing zoning and Plan designation either: Given the fact that the
applicant is a medical service provider (i.e. Peace Health); that they are pursuing these
applications; and th.at they have indicated on their application that the purpose of these
applications is to develop a future medical office clinic, it is highly likely (in Staff's
opinion) that they will pursue the medical office use as they've specified. As noted in the
"applicant's rebuttal, average wages and benefits for medical workers tends to be higher
than average local wages. Staff concurs with the applicant's rebuttal statement and .
affirms the original Staff Report findings indicating that the proposal is in compliance
with applicable Metro Plan policies.
. Ms. Senl's Submittal- Issue #6:. "The applicant makes the argument that the
proposed plan amendment andzone change would have the effect of correcting
existing non-conforming uses on TL #402, (map 17-02-32); however, the iooo
SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include the
subject property. It appears that the existing nonconforming uses were aCtually
established AFTER adoption of the 2000 SCLS, indicating that the existing uses
were actually permitted by the City with the knowledge thatthese uses would
create plan/zone conflicts."
Aoolicant's Rebuttal: "The applicant does not allege that there is a Plan/zone
conflict on Tax Lot 402; clearly the existing Plan designations and zoning are
LMl. Rather, the point made in our application narrative is that commercial uses
have existed for decades, pre~existing the establishment of the Metro Plan and the
application of the LMJ designation on the subject properties. Ms. Segel provid,es
no evidence to back up her accusation that the City wittingly allowed commerCial
uses on Tax Lot 402 after adoption of the SCLS. The applicant and owner of Tax
Lot 402 will provide additional evidence and testimony at the City Council
hearing on July 2 which will fllrther demonstrate factually that commercial uses
and employment have been in the building on Tax Lot 402 for nearly 50 years......
4-103
STAFF RESPONSE: Theexistinll zoninll for TL #402 is Lillht Medium Industrial
(LMI). The existinll Plan Desirnation for TL #402 is Lillht Medium Industrial (LMI).
Therefore, there is no Plan/zone conflict as alleged byMs. Segel. A non-conforming use
is not the same as a plan/zone conflict. Ms. Segel alleges that the City permitted the
existing uses on TL #402 "AFTER adoption of the 2000 SCLS..." and further states that
the uses were "...permitted by the City with the knowledge that these uses wouldcreate
plan/zone conflicts." This allegation has not merit for multiple reasons. Article 5 of the
Springfield Development Code provides provisions to allow existing non-conforming
uses to modify or expand based upon specific criteria. A "non-conforming use" is a use
that was legally created when first established but would not be allowed as a "new use"
under the existing zoning. The existing commercial uses on TL #402 are most likely
considered non-conforming uses (i.e. commercial uses on .industrial zoned property). The
2000 SCLS does not list TL #402 as a Plan/Zone conflict because it is not a plan zone
conflict.
Ms. Se!!el's Submittal- Issue #7: "The proposed change is not 'logical cmd
"harmonious' because it is not consistent with the development pattern envisioned
in the Metro Plan ...Compliance with statewide planning goals, including goals
2,6,9,10,12 and 13 has not been established. In particular, it has not been
established thatthe Eugene-Springfield Metro UGB area's supply of campus
industrial land will be protected pursuant to the PAPA and zone change
proposal... Staff has failed to address the impact that this proposal will have on
the dwindling supply of shovel ready industrial land inside the Springfield city
limits, including prior actions approving land use code amendments to the
campus industrial zone that established more flexibility' for what uses are
allowed in the city's campus industrial zones. "
Anolicant's Rebuttal: "It shouldfirst be noted that the application does not
involve or in any way affect the 'metro area's supply of campus industrial land. '
Moreover, the application has no effect upon Goal 10 (Housing), and has
elsewhere demonstrated compliance with Goal 12 and other 'i1Pplicable statewide
planning goals. My guess is that Ms. Segel and Nancy Falk. who appeared at the
June 4 hearing and requested the written record be left 'openfor a'week, both
vigorously appose the Plan amendment/zone change proposed for the Marcola
Meadows project. and are borrowing arguments to also object to this modest
request before the City... The contention that the proposal would not result in a
. .
'logical and harmonious' land use pattern is without substance 'or basis in fact,
and is not an approval criterion. As noted above and elsewhere in therecord, this
proposal is consistent with policies and provisions in the Metro Plan. its
Economic Element, supporting refinement plans (re., the SCLS and MILS) to the
Metro Plan, and Goal 9 alld other applicable statewide planning goals... "
STAFF RESPONSE: Ms. Segel refers to the existing zorung of the subject site as
"Campus Industrial" multiple times in her letter. The subject property is zoned and
. designated Light Medium Industrial. notCamous Industrial. As noted in the applicant's
rebuttal, the statement submitted by Ms. Segel indicating that the"... prop'osed change is
~_1 o.A
not 'logical and harmonious...'" isnot.a criterion of approval for these applications. Staff
have reviewed the proposal based upon the applicable criteria of appt(>val, and found that
it meets the criteria (with conditions) as written in. the Staff Report. The inventories of
cornmercial and industrial land have been evaluated and balanced with the relevant Metro
Plan policies to formulate the recommendation for approval with conditions. Specific
findings related to the Statewide Planning Goals have also been included in the original
Staff Report. '
,
4-105
GOAL ONE COALITION
~
Goal One is Citizen Involvement
City of Springfield Planning Commission
David Reesor
City of Springfield
225 Fifth Street
Springfield, OR 97444
June 12,2007
RE: ZON 2007-00012JLRP 2007-00013, Plan Amendment & Zone Change
Dear"Members of the Commission:
~-+:i"'~r"'?1"'1 rt_,".'"-"
r.... ,,___~', . , ~ '-' ,'I ,~.,' ~ ",' ,)
. -'-:" .__'-L.,..>
.JUN 1 2 2007
BY:- f./K...
The Goal One Coalition (Goal One) is a nonprofit organization whose mission is to provide
assistance and sUpport to Oregonians in matters affecting their communities. Goal One is
participating in these proceedings at the request of and on behalf of its membership residing in
Lane County. This testimony is presented on behalf of Goal One and its membership,
including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, as an individual.
1. Introduction
This proposal is for a site-specific Metro Plan Amendment / Refinement Plan Amendment and
a concurrent Zoning Map Amendment from Light Medium Industrial (LMI) to Community
Commercial (CC) within the Springfield city limits.
The subject site is located near 44th and Main Street (Highway l26).The site consists of two
parcels under separate ownerships, and is located on approximately 5.24 acres identified as
Tax Lots 400 and 402 on Assessor's Map No. 17-02-32-00. TL 400 (5.01 acres) has several
vacant buildings on site, including portable trailer type structures. The smaller of the two
subject lots, TL 402 (.24 acres), has an existing commercial development on-site, although the
plan designation imd zone are LMI. properties located to the north (Weyerhauser) are zoned
and designated heavy industrial. Parcels located west of the subject site are designated mixed-
use on the East Main Refinement Plan. Property located east and adjacent to TL #402 is built
out as a business park, and designated LMI. Properties located south of the subject site, across
Main Street, are zoned and designated Community Commercial..
II. Criteria applicable to the request
Local approval criteria are found in the following documents: Springfield Development
Code, Metro General Plan, and East Main ~efinement Plan, as indicated in the s.taff '
report.
"The proposed plan amendment must also be found to be consistent with applicable statewide
planning goals'. ORS'197.175(2)(a). Applicable goals include Goal!, Citizen Involvement,
Goal 2, Land Use Planning; Goal 9, Economy of the State; and Goal 12, Transportation. The
. .
Eugene office: 642 Charnelcon Suite 100 . Eugene 01\ 9740 I . 541-431-7059 . Fax 541-431.7078
Lebanon office: 39625 Almen Drive' Lebanon 01\ 97355' 541-258-6074' Fax 541-258-6810
www.goal1.org
4-106
GOAL ONECOAUTION
proposed plan amendment must also comply with administrative rules implementing
applicabie statewide planning goals.
III. Analysis
COMt'RJ:HENSlVF PI AN CONSISTENCY AND COMPLIANCE WITH
STATEWIDE GOALS. .
All comprehensive plan amendments are reviewable for compliance with the statewide
. planning goals. Residents of Rosemont v. Metro, 173 Or App 321 (2001); 1000 Friends of
Oregon v. Jacksoll County, 79 Or App 93, 97, 718 P2d 753 (1986), rev den 301 Or 445
(1987); Opus Development Corp. v. City of Eugene. 141 Or App 249, 254, 918 P2d 116
(1996).
Goal 2 _ Land Use Planning is: "To establish a land usp planning process and policy
framework as a basis for all decisions and actions related to use of land and to assure an
adequate factual base for decisions and actions~" Specifically, local land use actions "shall be
consistent with the comprehensive plans." Goal 2, Part L Furt(1er, the information upon
which land use decisions are made "shall be contained in the plan document or supporting
documents." Goa]l, Part L . .
In this case, the applicant relies heavily on the acknowledged 2000 Springfield Commercial
Lands Study (5CL5), which does not address the entire Metro UGB area, and is riot a
refinement plan of the Metro Plan. It is the 1992 Metropolitan Industrial Lands Study, that
does address the entire Metro UGB area, is part of the Metro Plan, and is reflected in the
Econornic Element of the Plan.
The proposed findings. rely on reports and other documents contammginventories,
assumptions, arid data that have not been established for the entire Metro UGB area, but rather
only for the Springfield portion of the UGB area. This material includes data used to justify
findings of compliance with goal 9. Any decision relying on such findings would not comply
with Goal 2.
GoalS
Concerning applicability of land inventories pursuant to Ordinance #6150 that
adopted the Springfield Natural Resource Study, staffs position is that inventories.
established pursuant to Goal 5 are relevant considerations in considering availability
of commercial and industrial land. However, that analysis (applicant's Attachrnent
"A" _ tables II-I, 11-2 and 11-3) actually show little or no impact on the commercial
lands inventory from Goal 5 protection measures, and provide little if any analyses of
land availability within the entire Metro UGB area, rather than just the Springfield
UGB area. Table 11-2, Analysis of Maximum Possible Impact on Supply of
Commercial Lands within the Springfield Urban Growth Boundary shows an impact
of 11.56 acres on Springfield's (not the urban growth boundary area in it's entirety)
commercial land supply.
Metro Plan/East Main Refinement Plan, ZON 2007 -DOO 12 - LRP 2007 -DOO 13
4-107
2
GOAL ONE COAUTION
Additionally, the analysis pursuant to Ordinance #6150 fails to account for lands ADDED TO
the corrirnercial inventory since 2000, including but not limited to the Gateway MDR site's
100 acres, providing a skewed picture of the actual cornrnercialland inventory.
To skew the picture even further, the analysis of maximum possible impact from Goal 5
protection measures on supply of industrial lands (Ordinance #6150, table.II-I).considers
ALL industrial lands within .the entire Metro UGB area, rather than just the Springfield portion
of the UGB, and does not provide a breakdown of number of industrially zoned acres in
Springfield vs. Eugene. The 2000 SCLS, however (Table 3-2) shows that the number oflight
medium industrial (LMI) acres by plan designation in the Springfield UGB area is 198.77,
while the number of LMI acres within the Eugene UGB is shown to be 1230.78, The
applicant fails to establish the relevancy ofthese tables to the current PAPA and zone change
proposal, considering that only about 16% of the Metro area ugb industrial land supply is
within the Springfield city limits.
i-':t,~~,.:
Goal 9- Economic Development is: "To provide adequate opportunities throughout the
state for a variety 'of economic activities vital to the "health, welfare, and prosperity of Oregon's
citizens, "
The Staff Report's Goal 9 findings are based upon the 1992 Industrial Land Study and the
2000 Commercial Land Study. Goal 2 requires that information upon which land use
decisiollS are made be contained.in the plan document or supporting documents.
OAR 660-015-0000(2), Part I Planning establishes that city, county, state and federal agency
and special district plans and actions related to land use shall be consistent with the
comprehensive plans of cities and counties and regional plans adopted under ORS Chapter.
268.
Goal 9 _ 660-009-0010 (4) establishes that for a post-acknowledgement plan amendment
under OAR chapter 660, division 18, that changes the plan designation ofland in excess
of two acres within an existing urban growth boundary from an industrial use designation
to a non-industrial use designation, or an other employment use designation to any other
use designation, a city or county must address all applicable planning requirements, and:
(emphasis added)
(a) Demonstrate that the proposed amendment iscorisistent with its most recent economic
opportunities analysis and (emphasis added) the parts of its acknowledged .
comprehensive plan which address the requirements of this division;
The applicant appears to rely heavily on inventory and policy statements established bY the
2000 SCLS in establishing that the proposal is consistent with the Goal 9 rule, However, the
applicant's analysis of the proposals' consistency with comprehensive plan Economic
Element policies found In the Metropolitan General Plan, Chapter III, B-l - B-7 is insufficient
and does not address the most significant policies that must be considered.
The proposal would decrease the City's campus industrial land inventory by yet another 5.24
acres" The applicant has not justified the conversion of scarce, shovel ready industrial land,
Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013.
4-108
3
GOAL ONE COAUTION
especially land designated and zoned light medium industrial inside the Metro UGB, even
though Metro Plan (comprehensive plan) Economic Element policy # 12 establishes that the
cities are to "discourage future Metropolitan Area General Plan amendments that would
change development ready industTIallands (sites defined as short - tehn in the metropolitan
Industrial Lands Special Study, 1991) to non-industrial designations." The applicant and staff
findings do not address how the loss of these 5.24 acres impacts the short-term supply ofLMI
designated land. . .
The applicant makes the argument that the proposed plan amendment and zone change would
have the effect of correcting existing non-conforming uses on TL #402. (map 17-02-32);
however, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include
the subject property. It appears that the existing nonconforming uses were actually established
AFTER adoption of the 2000 scLs, indicating that the existing uses were actually permitted
by the City with the knowledge that these uses would create plan/zone conflicts.
In addressing applicability of the Springfield Cornrrtercial Lands Study (2000 SCLS), the
applicant appears to try to separate the Metro Area by jurisdictional boundary. However,
Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial
Lands study. The jurisdictionally focused SCLS does not analyze supply and demand for the
entire Metro UGB area and cannot be relied upon on it's own to establish consistency with the
requirements of OAR 660-009-0010 (4), which establishes that the proposed PAPA be
consistent with both (emphasis added) the most recent economic opportunities analysis (i.e.
. the 2000 SCLS) and the comprehensive plan. .
A related problem with placing such heavy reliance on the 2000 SCLS to establish Goal 9
compliance is that in analyzing supply and demand, the study fails to consider or otherwise
account for lands added to the commercial inventory via applicant initiated and city approved
zone changes and plan amendments. One very obvious example of an addition to the
Springfield commercial lands inventory was the 2003 plan amendment and zone change (LRP
2003-0013 and ZON 2003-0019) at the 100-acre Gateway Medium Density Residential site
that had the effect of rezoning and redesignating 100 acres ofresidentialland to commercial.
The applicant provides a spreadsheet (their Attachment B) that supposedly accouri.ts for all
Metro Plan diagram changes affecting the supply of residential, commercial and industrial
Lands in the city of Springfield between 1991 and the present, but has failed to account for or
otherwise addreSs the addition of cornniercial land to the SCLS, even though it is clear that
more than 100 acres of comrnercialland has been added to the inventory since the year 2000.
This omission raises doubt as to the accuracy of applicant's Attachment B in supposedly
accounting for additions to and subtractions from the various land inventories.
The applicant also relies in part on inventories established in conjunction with adoption of
Springfield's Natural Resource (NR) Study, by Ordinance #6150' on November 28, 2005.
While those inventories may be relevant to this proposal in that possible 'impacts' resulting
from Goal 5 protection measures were considered for all zoning classifications, the analysis of
maximum possible impact on supply of commercial landS pursuant to the study is lirnited'to
the area .within the Springfield portion of the Metro UGB (table 11-2). Again, because
Eugene and Springfield share a UGB and a comprehensive plan, an analysis of the entire
UGB area is necessary to establish an accurate picture of the supply of commercia1'1ands.
Metro Plan/East Main Refinement Plan, ZON 2007 -00012 - LRP 2007-00013
4-109
4
GOAL ONE COAUTION
-
In any case, the NR Study found ,that the maximum possible impact of Goal 5 protection
measures on the Springfield Commercial Lands Inventory would be the loss of 11.56
Hcotnmercial acres."
LOSS OF INDUSTRIAL LAND
The proposed plan amendments and zone changes would remove 5.24 acres of shovel ready
light medium industrial land from the Metro UGB area industrial lands inventory. This is in
addition to an additional 56 acre conversion of campus industrial to community commercial
land less .than 2 miles away which is currently pending approval by the Springfield ci!)'
council. The applicant is vague about the purpose of the proposed plan amendment arid zone
change, noting that, with approval of the plan amendment and zone change, the uses could
include a possible future medical clinic, and the provision of family wage jobs. The applicant
has said nothing about the existence of their other 100' acre medical campus located within
about.5 miles of the subject properties proposed for plan and zone changes. .Given this fact,
the applicant has not justified the removal of shovel ready light medium industrial land for
commercial uses. This area within the Springfield city limits is already inundated with
commercial zoning and commercial uses, and approval of this proposal would contribute even
further to over commercialization within the city of Springfield.
The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive
plan (Metro Plan) (Chapter III, Section B) of the Plan as relevant to the proposed PAPA.'
The four Plan policies considered by the applicant as relevant to the supply of industrial land
are policies 1,2, 6,and II
Policy I is to Demonstrate a positive interest in existing and new industries, especially those
providing above wage job and salary levels, and increased variety of job opportunities, a rise
in the stJndard ofliving, and utilization of our existing comparative advantage in "thdevel of
education and skill of the resident labor force. However, the' applicant is not specific about
. what uses will be cited should the proposal be approved, and there is no way to know if in fact
above wage jobs and salaries.
Policy 2 is to encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force. Again, there is no way to
establish if the applicant will in fact utilize local and imported capital, skills etc. as no
commitment to a use has been established.
Policy 6 merely states: "Increase the amount of.undeveioped land zoned (emphasis added) for
light industrial and commercial uses correlating the effective supply in terms of suitability and
availability with the projections of demand."
This policy addresses zoning only, hot plan designation, and concerns the necessity of having
adequate supplies of land of both commercial and industrial designations. It says nothing
concerning the applicability of favoring one plan designation over the other,
Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013
4-110
5
GOAL' ONE COAUTION
Policy II is to encourage economic activities which strength~n the metropolitan area's
position as a regional distribution, trade, health, and service center. The applicant
asserts that the amendment (sic) ",ill facilitate the development of medical uses that
will serve the needs of the growing residential areas in east, south and southeast
. Springfii:1d, and strengthen the" metropolitan area's position as a premier locale for
healthcare services, consistent with this policy objective. Considering that their 2003
zone change and plan amendments were based on the assertions that. provision of
medical care pursuant to campus style medical facility development is the wave of the
future, and that the applicant already has established their dominance in the health care
market within the city limits, it has hard to fathom why they think another 5.24 acres
will somehow strengthen Springfield's position as a premier locale for healthcare
servIces.
The PAP A proposal must be consistent with the Economic Element of the Comprehensive
plan in it's entirety. A major omission found in the application and staff report is an analysis
of all the Metro Plan Economic Element policies other than the four addressed by the
applicant. The remaining 28 policies should be addressed in some manner. More
specifically, the following policies are directly relevant to the inventory of industrial)ands
throughout the Eugene-Springfield Metro UGB area,
5 _ Provide existing industrial activities sufficient adjacent land for. future expansion.
, .
This Plan provision is directly applicable because the subject properties are currently zoned
and designated to take advantage oflight medium industrial designation and zoning. This
proposal to eliminate more industrial zoning adjacent to existing and developed industrial'
zoning, plan designation; and uses is clearly inconsistent with the Metro Plan Economic
element, and if approved would have the effect oflirniting future growth and expaJ1Sion of the
existing campus industrial uses.. .
7 _ Encourage industrial park development, including areas for warehousing and distributive
industries and research and development activities.
Economic Element of the Metro Plan, Finding #17 establishes: "Special jight industrial firms"
"have varied site location requirements, prefer altemative sites to choose from, and usually
benefit from location cif other special light industrial firms within the community and within
the same industrial development." The subject site is located adjacent to an existing light
medium industrial site. '
9 - Encourage the expansi~n of existing and the location of new manufacturing activities
which are characterized by low levels of pollution and efficient energy use.
S taff has not discussed efforts to attract and/or encourage expansion of manufacturing.
activities that could be sited on campus industrial zoned and designated lands. The only
reference to this issue from staff is that there hasn't been much interest in the site from the
industrial development sector.
15 _ Encourage compatibility between industrially zoned lands and adjacent areas in local
planning program.
Metro Plan/East Main Refinement Plan, ZON 2007-D0012 - LRP 2007-D0013
4-111
6
GOAL ONE COAlITION
Neighbors have expressed no concern about their quality oflife from existing industrial uses.
The applicant has not addressed why or how the existing light medium industrial zoning and
plan designation is incompatible with the adjacent neighborhood zoning and plan designation.
16 _ Utilize processes and local controls which encourage retention oflarge parcels or
consolidation of small parcels of industrially or commercially zoned land to facilitate their use
or reuse in a comprehensive rather than piecemeal fashion. . ,
The subject properties are adjacent to a large parcel which is zoned and designated LMI. Staff
is directed by this policy to encourage retention of this parcel of industrially zoned and
designated land, which is one of the few remaining parcels ofLMI land within the Springfield
city limits.
21 _ Reserve several areas within the UGB for large scale, campus type, light manufacturing
uses:
Staff has failed to address the impact that this proposal will have on the dwindling supply of
shovel ready industrial land inside the Springfield city limits, includi.n.g prior actions
approving land use code amendments to the campus industrial zone that established rnore
:flexibility' for what uses are allowed in the city's campus industrial zones.
28 _ Recognize.the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood. .
This PAPA proposal requests community commercial plan designation and zoning yet has not
considered or otherwise addressed the applicability of neighborhood commercial zoning vs.
the requested community commercial zoning.
Staff and applicant have not addressed the applicability of community commercial zoning
within a node, or explained why neighborhood commercial zoning is being ignored for higher
intensity uses in this existing neighborhood.
All the Metro Plan Economic Element policies are applicable to this application, and should
have been addressed by the applicant.
Ill. Conclusion
The proposed plan amendment is not logical a'nd harmonious with. the land use pattern for
the greater area. The proposed change is not "logical and harmonious" because it is not
consistent with the development.pattern envisioned in the Metro Plan.' .
As explained above, the proposed amendment is inconsistent with the intent of the Economic
Element of the Metro Plan,and does not comply with Metro Plan policies. Therefore it cannot
be found to be compatible with these Plans.
Compliance with statewide planning goals, including goals 2, 6, 9, 10, 12, and 13, has not
been established. In particular, it has not been established that the Eugene-Springfield Metro
UGB area's supply of campus industrial land will be protected pursuant to the PAPA and zone
change proposal.
Metro Plan/East Main Refinement Plan. ZON 2007-00012 - LRP 2007-00013
" 4-112
7
GOAL ONE COALITION
"..
The requested plan amendment does not comply with policies of the Metro .Plan and
Metropolitan Industrial Lands Special Study.
The requested plan amendment and zone change does not benefit the public and are not
appropriate. "
Goal One and other parties whose addresses appear in the first paragraph of this' letter request
notice and a copy of any decision and findings regarding this matter.
Respectfully submitted,
Lauri Segel-
Community Planner
Metro Plan/East Main Refinement Plan, ZON 2007 -D0012 - LRP 2007 -D0013
4-113
8
~ PeaceHealth
June 13, 2007
Springfield Planning Commission
Attn: David Reesor, Planner
City of Springfield
Development Services Department
225 Fifth Street
Springfi~ld, OR 97477
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Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change
Dear Chairman Cross and Commissioners,
The Commission considered the above-referenced applications on June 5 at a duly
noticed work session and public hearing. The following rebuts written testimony
submitted by Lauri Segel of the Goal One Coalition at the close of the extended record
yesterday.
Ms. Segel suggests that the applications do not comply with statewide
planning Goal 9 (Economic Development) - and by extension with Goal 2
(Land Use Planning) - because the 2000 Springfield Commercial Lands
Study (SCLS) "does not address the entire Metro UGB area, and is not a
refinement plan ofthe Metro Plan." (pg. 2; June 12,2007 Segel letter)
She further states that "Eugene and Springfield have a shared and adopted
UGB, Comprehensive Plan, and Industrial Lands study. The
jurisdictionally focused SCLS does not analyze supply and demand for the
entire Metro UGB area and cannot be relied upon on it's [sic] own to
establish consistency wi th the requirements of OAR 660-009-00 I 0 (4),
which establishes that the proposed PAPA [Plan amendment] be
. consistent with both (emphasis added) the most recent economic
opportunities analysis (i.e., the 2000 SCLS) and the comprehensive plan."
(pg. 4, Segel letter)
ADDlicant's ResDonse: The SCLS was developed by the City and adopted by the
Springfield City Council (Resolution No. 00-13 and included in the end pages of the
SCLS) to comply with Goal 9 and applicable OARs pursuant to periodic review
requirements established by the Oregon Land Conservation and Development
Commission. Prior to the SCLS, the City of Eugene had an acknowledged plan for
complying with Goal 9, the 1992 Eugene Commercial Lands Study (ECLS). The ECLS
states: "The study includes solely the Eugene portion of the metropolitan urban growth
boundary." (pg. 1-3, ECLS)
Phon!:; (541) 686.3660
Fax: (541) 686-3699
PO Box 1479 Eugene OR 97440+1479
www.peacehealth.org
Dedicated to Exceprional Medicine
and Compassionate Care
4-114
Re: ZON 2007-00012, LRP .007-00013 - Plan Amendment/Zone Change
Applicant's Rebuttal
June 13 2007
Page 2
Although there is in fact an acknowledged study covering both communities' industrial
lands (the 1993 Metropolitan Industrial Lands Policy Report, and companion Inventory
Report), the ci'ties of Eugene and Springfield have separately adopted and acknowledged
commercial lands studies fulfilling the requirements of Goal 9. As such, the SCLS serves
as the City of Springfield's "most recent economic opportunities analysis," as Ms. Segel
notes above by her own admission. . The SCLS also complies with Metro Plan Policy 31
which called for the City to conduct a cornrnerciallands study, and fulfills the City's
Goal 9 requirements pursuant to the periodic review work order, now accepted as
complete by DLCD. There'is'no requirement that the Applicant or the City perform a
metro-wide analysis of commercial lands in order to adopt findings satisfying compliance
with Metro Plan policies and Goal 9.
Ms. 'Segel states that the analysis provided does not account for additions
to the inventory of commercial lands, notabiy "the' GateWilY MDR site's
100 acres." (pg. 4, Segel letter)
Aovlicant's ResDohse: The City previously adopted amendments to the Gateway
Refinement Plan (Jo. No. 2002-08-244), including GRP,lrnplementation Action 12.1,
'which limited redesignation and rezoning of up to 99 acres ofresidentialland within the
Gateway MDR site. Subsequent Plan diagram amendments and zone changes of 96.2
acres and 3.5 acres resulted in redesignation/rezoning of96.2 acres to Mixed Use.
Commercial or Medical Services of the possible 99 acres available under the GRP.
Considering that the SCLS identified a deficit of 158 acres in the supply of commercial
land over demand, accounting for this additional redesignated/rezoned land, this woul~
still result in a deficit of more than 61 acres of needed 'cornrnercialland. Approving the
requested Plan amendment/zone change would still leave a deficit of approximately 55
acres of needed cornrnercialland.
The supplemental information submitted into the record by the Applicant included the
City's analysis o.fimpacts to. the commercial lands inventory pursuant to the City's
acknowledged compliance with GoalS periodic review requirements. Table 11,-2 ofthis
analysis (see pg. 3-25 in the Commission'sJune 4, 2007 hearing packet) identifies that as
a consequence of the City's Goal 5 protection measures that approximately 11.5 acres
would be removed from the inventory of needed commercial lands, thus further adding to
the commercial lands deficit established in the SCLS:
Therefore, even considering impacts to commercial lands inventories f~om other adopted
and acknowledged plans (i.e., the City's plan for Goal 5 compliance) and acknowledged
Plan amendmentslzone changes, approval of the proposal will not result in there being an
excess of needed commercially zoned and designated land. To the contrary, this analysis
demonstrates that there will remain a deficit of approximately 66 acres after approval of
the requested redesignation/rezoning:.
f
4-115
Re: ZON 2007-00012, l;\U' .J07-00013 - Plan AmendrnentlZone Change
Applicant's Rebuttal
June 13" 2007
Page 3
Ms. Segel states that the application relies "heavily on inventory and
policy statements established by the 2000 SCLS in establishing that the
proposal is consistent with the Goal 9 rule. However, the applicant's
analysis ofthe proposals' consistency with comprehensive plan Economic
Element policies found in the MetropolitanGeneral Plan, Chapter III, B-1
~ B-7 is insufficient and does not address the most significant policies that
must be considered." (pg. 3, Segel letter)
She further alleges that the application hasn't "justified the conversion of
scarce, shovel ready industrial land, especially land designated and zoned
light medium industrial inside the Metro UGB, even though the Metro
Plan (comprehensive plan) Economic Element policy #12 establishes that
the cities are to 'discourage future Metropolitan Area General Plan .
amendments that would change development ready industpallands (sites
defined as short-term in the metropolitan Industrial LandsSpecial Study,
1991) to non-industrial designations.' The applicant and staff findings do
not address how the loss of these S.24 acres impacts the short-term supply
of LMI designated land."
Anolicant's Resoonse: The Applicant's original March IS, 2007 submittalincluded
findings addressing relevant Metro Plan policies (see pg. S of the submittal, pg. 4-S of the
Commission's June 4, 2007 hearing packet). Clearly not all ofthe 32 Metro Plan
Economic Element policies are relevant to the proposal. Many are aspirational in nature
and not directive to a specific quasi-judicial application, for example Policy 28:
"Recognize the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood." (pg. III-B-6, Metro Plan) Others are directed to
actions that the public sector jurisdictions are to undertake, such as Policy 3l, which
Springfield did in conducting in the SCLS: "Conduct a Commercial Lands Study prior to
the next major plan update." (pg. III-B-7, ibid) Nonetheless, to demonstrate that all
policies were considered irrespective of their applicability, the Applicant will provide
supplemental findings and enter them into the record prior to the City Council hearing on
" .
these applications. However, this does not suggest that the Applicant's findings are
presently inadequate or that the Metro Plan policies cited are not on point.
Ms. Segel's citation of Economic Element Policy 12 ignores the fact that the subject site
was not included among the sites "defined as short-term in the metropolitan Industrial
Lands Special Study, 1991)." The adopted and acknowledged Metropolitan Industrial
Lands Policy and Inventory Reports identify the subject site as being included in
"Subregion #8 _ East Springfield." Maps and tabular information in these reports (pp.
42-44, tables pp. 18-26; 1993 MIL Policy Report) do not identify the subject site among
the "short-term sites" in the industrial lands study, presumably because both were
considered developed" The abutting property now developed with the Hyland Business
Park was, however, identified in the study as site #7 in this subregion. While the Hyland
. property was included in the matrix of "short-term sites,:' it was also identified as being a
"developed" site. The MIL Policy Report states that "sites developed during the study
4-116
Re: ZON 2007-00012, LR.. .J07-00013 - Plan AmendmentlZnne Change
Applicant's Rebuttal
" June 13" 2007
Page 4
were not included in the short-term supply of sites. Staffprojected a five year need for
industrial sites based on development trenc\s in Eugene-Springfield during the previous
two year period,.a time of economic growth. This short term demand was compared to
the existing supply of sites, excluding those already developed. [emphasis in original
report]" (pp. 15, 16) Therefore, the subject site was not included in the inventory of
short-term industrial sites in the industrial lands study casting doubt on the applicability.
of Metro Plan Economic Element Policy 12~
Even if Policy 12 were relevant, its language is clearly not prohibitive to approval of an
application for redesignation/rezoning of an industrial site, particularly when considering
it in the context of industrial and commercial land inventories. As stated above and
established in the record, there is a demonstrated nel,:d for additional commercial land,
which the proposalhelps address.
The record also includes evidence demonstrating that there is a surplus of needed
industrial land. The acknowledged metro industrial lands study identified a surplus of
buildable light medium industrial acreage, and overall industrial acreage, in Eugene,
Springfield, and combined in the metro UGB. Table 5 in the MIL Inventory Report(pg.
47) identifies supplies of buildable industrial land as follows:
Eugene
Springfield
Metro UGB
LMI Acres
1,230.78
198.77
1,429.55
Total Industrial Acres
2,895.49
708.80
3,604.29
The report further states that the study "identifies about 1,688 constraint-free industrial
acres. .".. This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,172 acres." (pg. 73, MIL Inventory Report) .
As noted in the City's Goal 5 analysis entered into the record, the maximum impact of
industrial acreage from Goal 5 protection measures in Springfield is 54.43 acres (Table
" .
11.3, pg. 3-25 of the Commission's June 4 hearing packet). The analysis also found that
there were 90.80 acres removed from the industrial designation by prior Plan
amendments in Springfield. Therefore, even if all of the industrial acreage impacted by
Goal 5 arid all of the acreage redesignated in Springfield were from the LMI designation
_ which is no doubt not the case - there would still be a surplus of nearly 50 acres of LMl
designated land even after approval of the requested Plan amendment. This does not
account for the 11.5 acres of land added to the inventory of LMI zoned and designated
land referenced in my March 28,2007 supplemental information" .
Ther.efore, the removal of 5.24 acres of LMI zoned,and designated land will not result in
a deficit-of needed land in that industrial designation.
Moreover, although Economic Element Policy 12 "discourages" Plan amendments for
certain industrial lands, there are countervailing policies in the Metro Plan (i.e.,
4-117
"Re: ZON 2007-00012, LRP 2007-00013 - Plan AmendmentlZone Change
Applicant's Rebuttal
June 13" 2007
Page 5 .
Economic Element Policy 6) and SCLS (i"e., Policies I-A and I-C) that are directive to
providing an adequate supply of needed cornrnerciallands. The Metro Plan recognizes
such conflicts: "The respective jurisdictions recognize that there are apparent conflicts
and inconsistencies between and among some goals, objectives, and policies. When
making decisions based on the Plan, not all the goals, objectives, and policies can be met
to the same degree in every instance. Use of the Plan requires a 'balancing' of its various
components on a case~by-case basis, as well as a selection of those goals; objectives, and
policies most pertinent to the issue at hand." (pg. 1-4, Metro Plan) The Applicant
contends that findings and evidence in the record from adopted and acknowledged
sources demonstrate that approval of the requested redesignation/rezoning is consistent
with 'applicable policies and fulfills the City's employment-generating objectives and
requirements under Goal 9.
Ms. Segel's letter states that "the applicant is not specific,about what uses
will be cited should the proposal be approved, and there is no way to know
ifin fact [sic] above wage jobs and salaries." (pg.S, Segel letter)
She also states that while "the applicant argues that the proposal would
have the effect of correcting existing non-conforming uses on TL #402"
that the property is not included in the "Sites with Plan/Zone Conflicts" in
the SCLS. She goes on to state that "it appears that the existing
n0l1confom1ing uses were actually established AFTER adoption of the
2000 SCLS, indicating that the existing uses were actually permitted by
the City with the knowledge that these uses would create plan/zone
conflicts." (pg. 4, Segel letter)
Aoolicant's Resoonse:. The Applicant does not allege that there is a Plan/zone conflict on
Tax Lot 402; clearly the existing Plan designations and zoning are LMI. Rather, the
point made in our application narrative is that c,ommercial uses"have existed for decades,
pre-existing the establishment of the Metro Plan and the application of the LMI
designation on the subject properties. Ms. Segel provides no evidence to back up her
accusation that the City wittingly allowed commercial uses on Tax Lot 402 after adoption
of the SCLS. The Applicant and owner of Tax Lot 402 will provide additional evidence
and'testimony at the City Council hearing on July 2 which will further demonstrate
factually that commercial uses and employment have been in the building on Tax Lot 402
for nearly SO years.
Ms. Segel's assertion that the application was unspecific as to the future uses on Tax Lot
400 is inaccurate. The application narrative clearly states the intended purpose of the
redesignation/rezoning is to allow for a future medical clinic on Tax Lot 400 and to allow
the long-standing commercial operations on Tax Lot 402 to continue (pg. 2, pg. 4-2 in the
Commission's June 4 hearing packet). Such clinical uses are not permitted in any
industrial zoning district, thus prompting the need to rezone (and redesignate) Tax Lot
400 to allow a medical clinic. Average wages and benefits for medical workers tends to
4-118
Re: ZON 2007 -000 \2, LPJ' 2007 -000 \3 - Plan Amendment/Zone Change
Applicant's Rebuttal
June 13" 2007
Page 6
be higher than average local wages, and further substantiating data can be entered into the
record at the City Council level.
Ms. Segel contends that the proposal is not "logical and harmonious" with
. land use patterns in the greater area, inconsistent with the intent of the
Economic Element of the Metro Plan, doesn't comply with Metro Plan
policies, and hasn't demonstrated compliance with statewide planning
goals 2, 6, 9,10,12, and 13. "In particular, it has not been established that
the Eugene-Springfield metro area's supply of campuS industrial land will
be protected pursuant to the PAPA and zone change proposal."
Aoolicant's Response: It should first be noted that the application does not involve or in
any way affect the "metro area's supply of campus industrial land." Moreover, the
. application has no effect upon Goal I 0 (Housing), and has elsewhere demonstrated
compliance with Goal 12 and other applicable statewide planning goals. My guess is that
Ms. Segel and Nancy Falk, who appeared at theJune 4 hearing and requested the written
record be left open for a week, both vigorously oppose the Plan amendment/zone change
proposed for the Marcola Meadows project, and are borrowing arguments to also object
to thisrnodest request before the City. . .
The contention that the proposal would not result in a "logical and harmonious" land use
pattern is without substance or basis in fact, and is not an approval criterion. As noted
above and elsewhere in the record, this proposal is consistent with policies and provi;ions
in the Metro Plan, its Economic Element, supporting refinement plans (i.e., the SCLS and
MILS) to the Metro Plan, and Goal 9 and other applicable statewide planning goals.
On the basis of the record and arguments before you, we urge you to support the Staff
recommendation and forward to the City Council your recommendation approving the
pending applications.
,
Pnilip Farringt n, ,ICP
Director, Land Use Planning & Development
PeaceHealth Oregon Region
cc: Jim Werfelmann
Andrew Head
Shaun Hyland
4-119
.~----:::':'"l:~':"',',~.~';r':'
BEFORE THE PLANNING COMMISSION
OF THE CITY OF SPRINGFIELD
ORDER AND RECOMMENDATION
FOR A METRO PLAN I EAST MAIN
STREET REFINEMENT PLAN MAP
AMENDMENT AND A ZONING MAP
AMENDMENT
+
+
+
+
CASE NO. LRP2007-00013
CASE NO. ZON2007-00012
FINDING, CONCLUSIONS
AND RECOMMENDATIONS
RECOMMENDATION TO CITY COUNCIL
..<.
NATURE OF THE APPLICATION
This is a consolidated application for the above referenced case numbers. The applicant requests approval
of a Metro Plan I East Main Refinement Plan Map Amendment and a concurrent Zoning Map
Amendment on properties identified as Lane County Assessor's Map No. 17-02-32-00, Tax Lots 400 and
~02. The request involves two contiguous properties near 44'h and Main Street. Specifically, the applicant"
proposes to change Metro Plan designation from Light Medium Industrial to Commercial and a
concurrent Refinement Plan Map and a Zoning Map Amendment from LMl to Cc.
1. The subject appiications for a Metro Plan I Refmement Plan map amendment and Zoning Map
Amendment were submitted to the Development Services Department on March 16'h; 2007, and
deemed as complete on April 11 th, 2007. .
2. The application was submitted in accordance with Section 3.050 of the Springfield Development
Code. Timely and sufficient notice of the public hearing, pursuant to Section 14.030 of the
Springfield Development Code, has been provided.
3. On June 5th, 2007 a public hearing on the zone change request was held. The Development
Services Department staff notes including criteria of approv'al, findings and recommendations,
together "with the testimony and submittalS of the persons testifying at that hearing have been
considered and are part of the record of this proceeding.
4. On June 19th, 2007 the Planning Commission con,sidered additional information submitted into
the record as ofJune 13th, 2007.
CONCLUSION
(In the basis of this record, the proposed amendments "are consistent with the criteria of Sections 7.070,
8.030 and 12.030 of the Springfield Development Code. This general finding is supported by the specific
findings offact and conclusions in the attached staff report and attached hereto.
ORDER
It is ORDERED by the Planning Commission of Springfield that"approval of Case Number LRP2007-
00013 and ZON2007-00012, be GRANTED and a RECOMM~ATlON for approval forwarded to the
Spnngfield City Council. This ORDER was presented to a Il o..eft by the Planning Commission on
June 19'h, 2007. I
- -
PI ' . ni Co ' ission ChaIrperson
ATTEST:
AYES:
NOES:
ABSENT:
ABSTAIN:
.fL
gL
-k
--'-
" I "
Date ReceiVed:J:. Jjl rJ7
Planner: DR L